"The Federal Energy Regulatory Commission’s order on March 7 directed the development of a standard that addresses physical security threats and vulnerabilities and identified a path forward that focuses on the most critical facilities, incorporates risk management and further affirms foundational physical security efforts. NERC believes that the directive provides enough flexibility to avoid a prescriptive, lock-step regulation. As is the case for all cyber and physical security standards, they must be dynamic and adaptable to the constantly changing threat environment.
NERC commends FERC for outlining an approach in this directive that calls for a risk assessment to identify critical facilities. The requirement to identify potential threats and vulnerabilities to those facilities and develop a security plan without dictating the specifics steps to protect those facilities provides flexibility to the asset owners to address the range of physical security conditions in a responsive and cost-effective manner. NERC believes that this approach enhances physical security measures for the most critical facilities and lessens the overall vulnerability of the bulk power system. NERC has initiated the standards development process in response to the Commission’s order.
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