NEWS

PCS Consultants are committed to keeping up with the latest reliability compliance issues. Our consultants will be attending several upcoming events (listed below). Be sure to look us up and say hello. We’re excited to share how PCS can help you with your NERC Electric Reliability Compliance needs!

  • Ryan Carlson will be attending the September 18-19, 2012 NERC Critical Infrastructure Protection Committee (CIPC) meeting in St. Louis, MO.
  • Dale Zahn will be attending the October 2-3, 2012 RFC Reliability Workshop in Cleveland, OH.
  • Anita Swanson and Crystal Musselman will be attending the October 15-16, 2012 WECC CUG & WICF meetings in San Diego, CA.
  • Ryan Carlson will be attending the October 16-18, 2012 2nd Annual NERC Grid Security Conference in San Diego, CA.
  • Jason Phillips will be attending the October 17, 2012 WECC CIPUG meeting in San Diego, CA.
  • Ryan Carlson and Dale Zahn will be participating in the November 1-2, 2012 North American Generator Forum (NAGF) Conference in Atlanta, GA.

Today WECC issued its 2013 Compliance Audit Schedule.  If you'd like to download a copy, it is located in WECC's Compliance Library at http://www.wecc.biz/compliance/United_States/Pages/default.aspx.

PCS provides excellent audit preparation, education, and support services to our clients.  We have assisted clients both prior to and during their actual on-site and/or off-site audits.  If you'd like more information, please feel free to email or give us a call! 

PCS team member Dale Zahn is attending the NPCC Spring 2012 Compliance and Standards Workshop that is being held in Cooperstown, New York, May 30 - June 1, 2012.  Be sure to look him up.  He'll be happy to share with you what PCS is doing in the industry and how we can help you with your Reliability Compliance needs.

A number of clients have asked me if they should adopt the NERC CIP Version 4 'Brightline Criteria' into their NERC CIP Version 3 Risk-Based Assessment Methodology (RBAM), so I thought I would share my thoughts.  PCS attends several of the Regional CIP compliance user group meetings, and has heard repeatedly from regional audit teams and recently audited utilities that they should NOT adopt the brightline criteria until CIP Version 4 officially becomes effective.  The reason:  CIP-002-3 R1 requires that Responsible Entities have a "risk-based" (essentially impact-based) assessment methodology to identify Critical Assets.  While risk and impact were taken into account by the drafting team in creating the generic criteria used to identify Critical Assets in CIP Version 4, the criteria were not based on the impact of your assets on the Bulk Electric System.  Should you begin analyzing the impact of CIP Version 4 on your Critical Asset List?....Absolutely.  In the meantime, sit back, relax and enjoy the rest of the CIP Version 3 flight.  CIP Version 4 will be here before you know it.

Since several clients have asked questions about the effective date of NERC CIP Version 4 in the last few weeks, I thought I would share some answers.

The FERC approval date is June 25, 2012.

The effective date is April 1, 2014.

In the CIP Version 4 Implementation Plan, NERC has identified two categories (three scenarios) for existing Responsible Entities moving from CIP Version 3 to CIP Version 4.  I have paraphrased the three scenarios below:

Category 1 Scenario:  A Responsible Entity has previously undergone the CIP-002 Critical Asset identification process for at least one annual review and approval period, but has never identified any Critcal Assets (no CIP compliance program has been established).  New Critical Asset(s) have been identified as a result of the application of Version 4 "Brightline" criteria (Table 2, Category 1).  The implementation timeline is 24 months for the newly identified Critical Assets.

Category 2 Scenario:  A Responsible Entity has an established NERC Reliability Standards CIP compliance program in place and has identified new Critical Assets (planned changes excluded) as a result the application of Version 4 "Brightline" criteria (Table 2, Category 2).  The implementation timeline varies from 6 months to 18 months, depending on the requirement.

Compliant Upon Commissioning Scenario:  A Responsible Entity has an established NERC Reliability Standards CIP compliance program in place and, implements a new, upgrades, or replaces an existing asset that qualifies as a Critical Asset under the Version 4 "Brightline" criteria (Table 2, Category 2).  Critical Cyber Assets must also be compliant upon comnissioning.

Newly Registered Entities have several possible scenarios.  Details can be found for all of the scenarios in the CIP Version 4 Implementation Plan.

Are you looking for help with your CIP program? Proven Compliance Solutions can provide that help, customized to meet your compliance needs. PCS was founded by a team of professionals with extensive and diverse electric utility experience, who are passionate about helping entities manage the ever-increasing burden of NERC/Regional compliance. PCS staff members have earned industry respect for delivering excellence in compliance support, assessment, mock audits/gap analysis, documentation and ICP development, implementation, and management. Contact us today!

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