The American Public Power Association recently joined with other trade associations in submitting comments in separate proceedings at the Federal Energy Regulatory Commission on reliability matters.
Improving Reliability Enforcement
The North American Electric Reliability Corporation proposed enhancements to its compliance and enforcement practices in a November filing with FERC.
NERC proposed to: (1) speed processing of compliance exceptions and (2) introduce an "abeyance period" for certain new standards during which responsible entities must comply but auditors will not impose penalties for good faith implementations.
APPA -- jointly with the Electric Power Supply Association, Large Public Power Council, and Transmission Access Policy Study Group -- submitted supportive comments, highlighting the importance of implementing NERC’s proposed changes consistently with the existing Rules of Procedure to ensure stakeholders’ rights are not constrained by the proposed changes.
Internal Network Security Monitoring
APPA -- jointly with the Edison Electric Institute, National Rural Electric Cooperative Association, EPSA, and LPPC -- commented on FERC’s notice of proposed rulemaking on internal network security monitoring.
INSM refers to the practice of monitoring secure networks for unusual behavior, rather than just securing the entry points to a network.
NERC developed a reliability standard that will require entities with certain medium- and high-impact cyber systems to implement INSM.
FERC has proposed to accept that reliability standard and proposed to direct further changes -- within 12 months -- to expand the INSM requirements to electronic access control or monitoring systems (e.g., electronic firewalls) and physical access control systems (e.g., keycard systems).
The groups support approving the existing standard and urged FERC not to adopt the proposed directive for further changes.
If FERC nevertheless does adopt the directive, then it should do so in the most flexible way possible and allow for substantially more than twelve months to develop the revisions, the groups said.
