Balloting and commenting for this project are in the Standards Balloting & Commenting System (SBS).
A 45-day formal comment period for CIP-014-2 – Physical Security is open through 8 p.m. Eastern on Thursday, April 9, 2015. Ballot pools are being formed through March 23, 2015. An initial ballot and non-binding poll of the associated Violation Risk Factors and Violation Severity Levels will be conducted March 31 through April 9, 2015.
The draft RSAW is posted for feedback through 8 p.m. Eastern, April 9, 2015
To comment in the SBS, you must have a contributor, voter, or proxy role.
To join a ballot pool and vote in the SBS, you must have a voter role.
To be a proxy and vote in the SBS, you must have a proxy role.
To register to become a proxy or voter in the SBS:
· Go to ‘My User Profile’
· Select ‘Click Here’ to request additional permissions
· Select ‘Voter’ or ‘Proxy Voter'
The NERC Board of Trustees adopted the CIP-014-1 standard at their May 13, 2014 meeting and NERC staff is preparing the FERC filing.
CIP-014-2: In Order No. 802 (final order on CIP-014-1 – Physical Security), issued on November 20, 2014, the Federal Energy Regulatory Commission (FERC) directed NERC to remove the term “widespread” from Reliability Standard CIP-014-1 or, alternatively, to propose modifications to the Reliability Standard that address FERC’s concerns. FERC directed that NERC submit a responsive modification on July 27, 2015.
CIP-014-1: This project will address the directives issued in the FERC Order on Reliability Standards for Physical Security Measures under Docket No. RD14-6-000 issued March 7, 2014. The Commission directed "The North American Electric Reliability Corporation (NERC), as the Commission-certified Electric Reliability Organization (ERO), to submit for approval one or more Reliability Standards that will require certain registered entities to take steps or demonstrate that they have taken steps to address physical security risks and vulnerabilities related to the reliable operation of the Bulk-Power System. The proposed Reliability Standards should require owners or operators of the Bulk-Power System, as appropriate, to identify facilities on the Bulk-Power System that are critical to the reliable operation of the Bulk-Power System. Then, owners or operators of those identified critical facilities should develop, validate and implement plans to protect against physical attacks that may compromise the operability or recovery of such facilities. The Commission directs NERC to submit the proposed Reliability Standards to the Commission within 90 days of the date of this order."
Standard(s) Affected - CIP-014-1, CIP-014-2
CIP-014-2: FERC noted that incorporating the undefined term “widespread” in Reliability Standard CIP-014-1 introduces excessive uncertainty in identifying critical facilities under Requirement R1. As FERC stated in its earlier March 7, 2014 Order, only an instability that has a “critical impact on the operation of the interconnection” warrants finding that the facility causing the instability is critical under Requirement R1. The March 7 Order did not intend to suggest that the physical security Reliability Standards should address facilities that do not have a “critical impact on the operation of the interconnection.” FERC stated that this understanding is unintentionally absent in Requirement R1 because the requirement only deems a facility critical when, if rendered inoperable or damaged, it could result in widespread instability, uncontrolled separation, or Cascading within an Interconnection. The definition in Requirement R1 should not be dependent on how an applicable entity interprets the term “widespread” but instead should be modified to make clear that a facility that has a critical impact on the operation of an Interconnection is critical and therefore subject to Requirement R1.
CIP-014-1: From the Order: "Physical attacks to the Bulk-Power System can adversely impact the reliable operation of the Bulk-Power System, resulting in instability, uncontrolled separation, or cascading failures. However, the current Reliability Standards do not specifically require entities to take steps to reasonably protect against physical security attacks on the Bulk-Power System. Therefore, to carry out section 215 of the FPA and to provide for the reliable operation of the Bulk-Power System, the Commission directs the ERO to develop and file for approval proposed Reliability Standards that address threats and vulnerabilities to the physical security of critical facilities on the Bulk-Power System. Such Reliability Standards will enhance the Commission's ability to assure the public that critical facilities are reasonably protected against physical attacks."