tag:blogger.com,1999:blog-1987420974894463968.post8652763182578206929..comments2024-03-21T03:56:54.312-05:00Comments on Tom Alrich's Blog: FERC Order 791Tom Alrichhttp://www.blogger.com/profile/11926296316487964077noreply@blogger.comBlogger4125tag:blogger.com,1999:blog-1987420974894463968.post-46251750274246188262013-12-04T17:50:51.530-06:002013-12-04T17:50:51.530-06:00Tim Kelley pointed out that the Federal Register e...Tim Kelley pointed out that the Federal Register entry specifically says Feb. 3 is the effective date. And with my typical sleuthing, I figured out why: Feb. 1 is a Saturday!Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-23890029131316673702013-12-03T20:32:24.029-06:002013-12-03T20:32:24.029-06:00Tim Kelley of SMUD pointed out that the CIP V5 Fin...Tim Kelley of SMUD pointed out that the CIP V5 Final Rule (which includes Order 791) was published today Dec. 3 in the Federal Register. Since the effective date of V5 is 60 days later, I believe this makes that date Feb. 1, 2014 (not Feb. 3, as Tim and one other person said). I'm certainly willing to be corrected on that, however. In any case, we know early Feb. is the date.Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-3413485474341771262013-12-02T20:39:36.915-06:002013-12-02T20:39:36.915-06:00An anonymous informed reader pointed out a strikin...An anonymous informed reader pointed out a striking fact to me: Even though FERC orders NERC to develop new requirements for Low impact systems and for transient cyber assets, they don't specify this has to be done in a year (whereas they do for the directive that IAC be removed). So the question is: Is this a mistake, or does FERC really intend to make these open-ended (not likely at all)?Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-89725665656585627602013-12-02T20:34:03.582-06:002013-12-02T20:34:03.582-06:00Scott Smith of Portland General Electric passed on...Scott Smith of Portland General Electric passed on the reason why V5 won't be effective until 60 days after publication in the Federal Register (while some other orders are effective upon publication): This is a "major rule" and thus must be submitted to both houses of Congress and to the GAO. It seems they have the power to veto or at least question it, if they want (God help us if they do!), but they have to do so within 60 days. See paragraph 269 of the order.Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.com