• NERC Completes Grid Security Exercise; FERC Accepts NERC Compliance Filing on Planning Criteria
  • November 21, 2013 | Authors: Peter S. Glaser; Kevin C. Greene; Daniel L. Larcamp; Clifford S. Sikora; Lara L. Skidmore
  • Law Firms: Troutman Sanders LLP - Washington Office ; Troutman Sanders LLP - Atlanta Office ; Troutman Sanders LLP - Washington Office ; Troutman Sanders LLP - Portland Office
  • On November 13 and 14, 2013, the North American Electric Reliability Corporation (‘NERC”) completed its international biennial Grid Security Exercise (“GridEx”) - a series of exercises that simulate cyber and physical attacks on the bulk power system.  The simulated exercises at GridEx are designed to test participating entities’ physical and cyber security procedures in response to a coordinated, disruptive attack.

    The 2013 GridEx marked the second time that NERC has conducted such simulations, with the first occurring in 2011.  The simulated events allow participating entities to experience real-time training in response to a cyber security attack.  According to NERC, GridEx allows participating entities to assess their performance of reliability standards CIP-001, CIP-008, CIP-009, EOP-004, EOP-008, and OE-417.  NERC stressed that the events would only be simulated and that no power outages would occur during the simulations.  NERC is expected to eventually publish its findings from GridEx in early 2014.

    Meanwhile, on November 13, 2013, FERC issued an order accepting NERC’s compliance filing evaluating the criteria Planning Coordinators use when identifying whether or not sub-200 kV circuits are subject to the Reliability Standard PRC-023-2, which governs transmission relay loadability.  NERC’s compliance filing was in response to Order Nos. 733 and 759, which required NERC to test the criteria on a sample group of utilities and report the findings to FERC.

    In its compliance filing NERC noted that all criteria (B1-B5) of Attachment B of the Reliability Standard PRC-023-2 are necessary.  NERC stated that each criterion allows for different evaluations that the other criterion do not address.  Furthermore, NERC explained that its base cases used criteria B4 to evaluate peak summer load for a term of one to two years on circuits that are in-service or have a significant chance of being placed in-service.  Additionally, NERC explained that criteria B5 will give a planning coordinator the opportunity to identify additional facilities subject to the reliability standard that are not available within the B1-B4 criteria.  Lastly, NERC explained that the results of its testing demonstrated that the criteria were comprehensive enough to identify all circuits that could affect the reliability of the bulk power system.

    FERC agreed with NERC’s evaluation of the criteria and the resulting conclusions.  Additionally, FERC viewed NERC’s responses to its additional questions as sufficiently comprehensive and therefore accepted NERC’s compliance filing.