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FERC Seeks Comment on Modification to Control Center Cybersecurity Rules

On July 21, prompted by cyberattacks highlighting cyber system vulnerabilities that may be exploited to attack the operation and maintenance of interconnected networks, FERC sought comment from industry participants on possible modifications to the CIP Reliability Standards that could address the cybersecurity of control centers used to monitor and control the BES in real time.

The Commission seeks comment on the following:

  • The operational impact of forming a separation between the internet and BES control center cyber systems performing transmission operator functions through use of physical (hardware) or logical (software means).

  • Whether rules should be implemented concerning “application whitelisting,” computer administration practices that would prevent unauthorized programs from running on a system network. FERC believes that application whitelisting could be a more effective mitigation tool than other mitigation measures because whitelisting allows only software applications and processes that are reviewed and tested before use in the system network.

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About this Author

J. Daniel Skees, Energy attorney, Morgan Lewis
Partner

J. Daniel Skees represents electric utilities before the Federal Energy Regulatory Commission (FERC) and other agencies on rate, regulatory, and transaction matters. He handles rate and tariff proceedings, electric utility and holding company transactions, reliability standards development and compliance, and FERC rulemaking proceedings. The mandatory electric reliability standards under Section 215 of the Federal Power Act are a major focus of Dan’s practice. He advises clients regarding compliance with reliability standards, and helps them participate in the...

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Serge Agbre, Morgan Lewis, Energy Lawyer, FERC Compliance,
Associate

Serge Agbre represents electric, natural gas, and other energy industry participants in a variety of regulatory, transactional, and litigation matters before the Federal Energy Regulatory Commission (FERC). His practice includes related court appeals. Serge represents clients in enforcement matters, rate proceedings, certificate proceedings, and National Environmental Policy Act (NEPA) matters connected to gas infrastructure projects. He also represents electric utilities in rate proceedings, tariff proceedings, and reliability standard compliance and enforcement matters. Serge is admitted in New Jersey only, and his practice is supervised by DC bar members.

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