FERC adopts grid physical security reliability standard

As expected, federal regulators have approved a new physical security standard for the high-voltage electricity grid.

On November 20, the Federal Energy Regulatory Commission approved Reliability Standard CIP-014-1 (Physical Security).  The standard, proposed by Commission-certified Electric Reliability Organization North American Electric Reliability Corporation (NERC), is designed to enhance physical security measures for the most critical parts of the nation's "bulk-power system," the high-voltage backbone of the nation's electric grid.

In the wake of a 2013 California incident in which a major substation was damaged by gunfire, in March 2014 the FERC directed NERC to prepare a draft standard to protect the physical security of the grid.  In response, NERC proposed a standard requiring owners and operators of transmission facilities toidentify and protect critical transmission stations, substations, and control centers whose damage through physical attack could result in spreading outages or other reliability problems.

On November 20, 2014, the FERC issued its Order No. 802 approving the physical grid reliability standards.  In a press release, the Commission described Order No. 802 as enhancing the physical security for the most-critical Bulk-Power System facilities and reducing the overall vulnerability of the grid to attacks.

As described by the FERC in Order No. 802, Reliability Standard CIP-014-1 has six requirements:

• Requirement R1 requires applicable transmission owners to perform risk assessments on a periodic basis to identify their transmission stations and substations that, if rendered inoperable or damaged, could result in widespread instability, uncontrolled separation , or cascading within an Interconnection. Requirement R1 also requires transmission owners to identify the primary control center that operationally controls each of the identified transmission stations or substations.
• Requirement R2 requires that each applicable transmission owner have an unaffiliated third party with appropriate experience verify the risk assessment performed under Requirement R1. Requirement R2 states that the transmission owner must either modify its identification of facilities consistent with the verifier’s recomme ndation or document the technical basis for not doing so. In addition, Requirement R2 requires each transmission o wner to implement procedures for protecting sensitive or confidential info rmation made available to third - party verifier s or developed under the Reliability Standard from public disclosure.
• Requirement R3 requires the transmission owner to notify a transmission operator that operationally controls a primary control center identified under Requirement R1 of such identification to ensure that the transmission operator has notice of the identification so that it may timely fulfill its obligations under Requirements R4 and R5 to protect the primary control center.
• Requirement R4 requires each applicable transmission owner and transmission operator to conduct an evaluation of the potential threats and vulnera bilities of a physical attack on each of its respective transmission stations, transmission substations, and primary control centers identified as critical in Requirement R1.
• Requirement R5 requires each transmission owner and transmission operator to develop and implement documented physical security plans that cover each of their respective transmission stations, transmission substations, and primary control centers identified as critical in Requirement R1.
• Requirement R6 requires that each transmission owner and transmission operator subject to Requirements R4 and R5 have an unaffiliated third party with appropriate experience review its Requirement R4 evaluation and Requirement R5 security plan. Requirement R6 states that the transmission owner or transmission operator must either modify its evaluation and security plan consistent with the recommendation, if any, of the reviewer or document its reasons for not doing so. Requirement R6 also requires each transmission owner to implement procedures for protecting sensitive or confidential information made available to third-party reviewers or developed under the Reliability Standard from public disclosure

While the Commission adopted the standard, it directed NERC to submit an informational filing within 2 years that addresses whether the physical security reliability standard should be applicable to additional control centers.  It also gave NERC 6 months to propose modifications to clarify the use of the phrase "widespread" instability in Requirement R1.

The FERC's rule will become effective 60 days after its publication in the Federal Register.