tag:blogger.com,1999:blog-1987420974894463968.post509814678384702520..comments2024-03-21T03:56:54.312-05:00Comments on Tom Alrich's Blog: The News from SPP and WECC, Part I: “Programmable”Tom Alrichhttp://www.blogger.com/profile/11926296316487964077noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-1987420974894463968.post-12008739992887950812015-06-16T21:01:08.399-05:002015-06-16T21:01:08.399-05:00Kevin Perry of SPP emailed me to point out that I ...Kevin Perry of SPP emailed me to point out that I had “misquoted” him when I noted in the second footnote that he had said the definition of “Programmable Electronic Device” from the January draft Lesson Learned would “probably have been used” by NERC entities to remove many devices – including relays – from being in scope for CIP v5 (I of course didn’t mention his name in the post, but since he’s a well-known figure in the CIP world many people probably drew the conclusion he had said it). Kevin says he really said – and I’m not disputing this – that, had the LL gone through (and had the Memorandum not been published in April), these devices could potentially have been removed from being Cyber Assets, leaving a large portion of the grid unprotected.<br /><br />As I said in the footnote, I talked with a number of people who said they had never heard of – nor considered on their own – the idea that the Lesson Learned on PED would have removed relays and other devices. In fact, after that post I confirmed with the person in charge of compliance at probably the largest manufacturer of devices used in substations that they hadn’t heard of this from a single customer. However, I don’t dispute the idea that at some point in the future there could have been a general realization that the LL provided a great “get out of jail free” card for relays, RTUs, etc. So I am correcting my statement.<br /><br />However, there’s a bigger issue for NERC here. They are saying their main motivation for issuing the Memorandum on PED was that a change was needed to prevent a serious danger to the BES. Let’s stipulate there was a danger – how can that possibly be a motivation for issuing the Memorandum? The Memoranda are supposed to be based on the “plain wording of the standard” and the “record of development”; indeed, the PED Memorandum quotes from several sections in NERC’s 7,000-page filing of comments they made with the CIP v5 standards. <br /><br />I thought the reason for issuing this and the other Memoranda was that NERC had suddenly found this wording in the filing, and realized it offered guidance that needed to be spread to the community immediately. Now it seems the Memorandum was in effect a new definition of PED, developed because NERC saw a clear and present danger caused by their previous definition in the Lesson Learned. I thought new definitions required a SAR. Are we now jettisoning the standards development process because of the need to meet the 4/1/16 compliance date? What are we going to jettison next? Rather than throwing away the Rules of Procedure, why don’t we push back the compliance date instead, so we can deal with these issues in the proper and legal manner? <br />Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.com