NERC CIP-002-5 1,500 MW Calculation

NERC CIP-002-5 is the starting point for determining which Cyber Assets need CIP protections. Entities are required to evaluate their Bulk Electric System (BES) assets according to Attachment 1. The attachment lists criteria for High, Medium, and Low BES Cyber Assets. Everything appears to be very straight forward, but what about Criteria 2.11? Does non-BES generation count towards the 1,500 megawatts (MW) threshold? NERC (unofficially) says it does.

Criteria 2.11 states: "Each Control Center or backup Control Center, not already included in High Impact Rating (H) above, used to perform the functional obligations of the Generator Operator for an aggregate highest rated net Real Power capability of the preceding 12 calendar months equal to or exceeding 1500 MW in a single Interconnection."

The issue gets fuzzy in situations such as Control Centers that manage renewable generation because many solar and wind facilities do not have enough mega volt amps (MVA) to be BES facilities. The definition of BES generation is generation connected at at least 100 kilovolts (kV) with individual nameplate rating greater than 20 MVA or plant/facility aggregate nameplate rating greater than 75 MVA.

PCS has been taking the conservative approach that non-BES generation counts towards the 1,500 MW threshold. However, there has been some confusion throughout the industry. PCS had a recent phone conversation with a member of the CIP team at NERC regarding this topic. The member of NERC confirmed that non-BES generation counts and was surprised there was confusion about this. Unfortunately, the person at NERC declined to provide a written response to PCS' email, but based on the conversation with NERC, PCS suggests that entities that have Control Centers evaluate all generation within a single Interconnection, whether BES or non-BES, to see if the total is equal to or exceeding 1,500 MW.

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