A standard to enhance physical security at critical power system facilities submitted by the North American Electric Reliability Corp. (NERC) will need modifications before it can be approved, the Federal Energy Regulatory Commission (FERC) said last week. 

FERC ordered NERC on March 7 to develop and submitnew reliability standards requiring owners and operators of the bulk power system to address risks due to physical security threats and vulnerabilities. The order directed NERC to require that owners perform a risk assessment of their systems to identify critical facilities; evaluate potential threats to, and vulnerabilities of, those facilities; and develop and implement a security plan to protect against attacks on those facilities.

But while NERC’s proposed reliability standard “largely satisfies” the directives in the March order, FERC proposed to direct NERC in a Notice of Proposed Rulemaking (NOPR) to make two modifications. One would specifically allow governmental authorities to add or subtract facilities from the entity’s list of critical facilities, even though those entities, including FERC or another appropriate federal or provincial authority, would exercise that authority “only rarely,” FERC said.

The second proposed modification will require NERC to revise wording that it believes could narrow the scope and number of identified critical facilities.

“Specifically, the NOPR seeks comment on the Commission’s concern that NERC’s use of the phrase ‘widespread instability’ rather than ‘instability,’ as stated in the March order, could create ambiguity since the term ‘widespread’ is not defined,” FERC said.

FERC also proposed to direct NERC to submit two informational reports to the commission. One would analyze whether the physical security standard should be applicable to additional types of facilities, consistent with the scope of critical facilities under other Critical Infrastructure Protection standards. In a second proposed report, NERC would provide analysis on grid resiliency, exploring what, besides the steps required by the proposed reliability standard, can be done to maintain the reliable operation of the bulk power system when faced with loss of critical facilities.

FERC’s NOPR provides for 45 days for public comment and a 15-day reply period, after which a final rule will be issued.     

Sonal Patel, associate editor (@POWERmagazine, @sonalcpatel)