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Electric Reliability Update - April 18, 2018

NERC

NERC Publishes Lessons Learned Report from GridEx IV - March 30 - In its Lessons Learned report, NERC identified recommendations and lessons learned after its fourth grid security exercise which took place in November 2017.  Overall, the feedback from participating organizations was positive and the objectives that had been set out prior to the event (exercise incident response plans, expand local regional response, engage critical interdependencies, improve communication, gather lessons learned and engage senior leadership) had been met.  NERC recommends, among other things, to consider whether the diversity of fuel sources presents a vulnerability to common mode failures or disruptions, and for utilities to develop and maintain communication contingency plans that use multiple technologies so that communication resiliency is maintained in the event one or more channels are lost.  GridEx V is scheduled for November 2019.

NERC Submits Transmission Planning Assessment Informational Filing - March 30 - NERC submitted to FERC an informational filing on the use of Reliability Standard TPL-001-4 (specifically Table 1, footnote 12) in compliance with FERC Order No. 786. TPL-001-4 is a Transmission System Planning Performance Requirement which requires planning coordinators and transmission planners to perform planning assessments. Table 1 of the standard contains a series of planning events and describes system performance requirements for a range of potential system contingencies required to be evaluated by the planner.  Footnote 12 provides specific parameters for the permissible use of planned Non-Consequential Load Loss to address Bulk Electric System performance issues. 

NERC Submits 2018 Standards Report, Status and Timetable for Addressing Regulatory Directives - March 30 - In accordance with Section 321.6 of its Rules of Procedure, NERC submitted the 2018 Standards Report, Status and Timetable for Addressing Regulatory Directives.  The Directives Report gives a breakdown of NERC’s activity and the status of all directives in the past year. Since NERC’s 2017 report 2017, the FERC has issued one directive and NERC filed petitions with FERC addressing 13 directives.  Currently, there are 13 outstanding directives, six of which NERC is addressing through existing standards development current projects.  The other outstanding directives are not related to Reliability Standards development (relating, for instance, to data gathering, registration, or the performance of research/studies) and are being addressed through other mechanisms.

Cybersecurity

DOE Announces Investment in Critical Energy Infrastructure - April 16 - The U.S. Department of Energy’s Office of Electricity Delivery and Energy Reliability announced a $25 million funding opportunity announcement (FOA) to support innovative research for the development of next-generation cybersecurity technologies.  Under the FOA, DOE’s Cybersecurity for Energy Delivery Systems program seeks applications to expand the development and adoption of energy technologies that will help ensure a more secure, resilient, and reliable electricity system.  Selected projects will promote advancement in five areas:

  • Redesign for Cyber-resilient Architecture – Electric and Oil and Natural Gas (ONG) Subsectors

  • Cybersecurity for the ONG Environment

  • Cybersecure Communications

  • Cybersecure Cloud-based Technologies in the Operation Technology (OT) Environment

  • Innovative Technologies that Enhance Cybersecurity in the Energy Sector

Applicant submissions are due June 18, 2018.  More information on the FOA can be found here.

Natural Gas Pipeline Hit with Cyber Attack - April 3 - Oil and Gas pipeline service provider Energy Transfer Partners LP was targeted in a cyber attack that shutdown communication systems.  The attack infiltrated a widely used electronic data interchange through third-party service provider, Energy Services Group LLC, which offers logistical support to major oil and gas companies.  The cyber attack had no effect on the flow of natural gas and has yet to be tied to previous attacks on the energy grid.

© 2019 Van Ness Feldman LLP

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About this Author

Malcolm C. McLellan, Van Ness Feldman Law Firm, Seattle, Cybersecurity and Energy Law Attorney
Partner

Malcolm’s practice focuses on the generation, transmission, and distribution of electric energy and regulated businesses. Malcolm has an intricate knowledge of the technical, legal, and business considerations facing electric utilities.  He regularly advises on Open Access Transmission Tariff and business practice compliance issues, reliability standards, standards of conduct, market behavior rules, interlocking director rules, electronic quarterly reporting, and accounting rules. He has significant experience with developing comprehensive energy compliance programs;...

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Suzanne Keppeler, Van Ness Feldman Law Firm, Energy and Gas Attorney
Of Counsel

Suzanne Keppeler focuses her practice on the representation of electric and natural gas utilities and oil pipeline companies on a wide range of regulatory matters before the Federal Energy Regulatory Commission (FERC) and U.S. Courts of Appeal. She counsels various clients on rate development, contract and tariff provisions, regulatory compliance and investigation defense, administrative litigation, and transactional matters. She also advises on compliance with North American Electric Reliability Corporation (NERC) and regional reliability standards, including self-reports, spot checks, formal audits and enforcement actions involving NERC and FERC’s Office of Enforcement.

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Darshana Singh, Van Ness Feldman Law Firm, Washington DC, Cybersecurity and Energy Law Attorney
Associate

Darsh Singh assists clients and firm professionals in the energy regulatory arena. Prior to joining Van Ness Feldman, Darsh served as a law clerk in the Office of Administrative Litigation at the Federal Energy Regulatory Commission (FERC) and interned at the Federal Trade Commission (FTC).   While at FERC, Darsh assisted Trial Staff in natural gas and oil pipeline rate proceedings and conducted research on market-based rates.   During her time at the FTC, Darsh focused on complex antitrust and consumer protection issues. 

While at The George...

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