By Kathy Larsen

Responding to concerns raised by last spring’s sabotage of a Pacific Gas and Electric substation, the Federal Energy Regulatory Commission has ordered development of reliability standards to protect the grid from physical attack.

The North American Electric Reliability Corp.’s standards, due in 90 days, do not have to require uniformity, FERC said in its order to NERC, nor are they likely to apply to the majority of facilities (RD14-6). NERC CEO Gerry Cauley and FERC commissioners Philip Moeller and John Norris warned last month that an overreaction to the threat could be expensive and counterproductive. (See FERC-NERC: Don’t Overreact to Sabotage Threat.)

Identify Critical Facilities

NERC’s standards must require owners and operators to take at least three actions. The first step is a risk assessment to determine what facilities, if damaged, could have a critical impact on grid operations.

The next steps are to evaluate potential threats and vulnerabilities to those critical facilities and then to develop and implement security plans.

FERC told NERC to include a procedure that would ensure confidential treatment of sensitive information but still allow appropriate oversight for compliance.

“The commission is not requiring NERC to adopt a specific type of risk assessment, nor is the commission requiring that a mandatory number of facilities be identified as critical facilities,” the order said. It added that FERC “expects that critical facilities generally will include, but not be limited to, critical substations and critical control centers.”

Once facilities are identified, FERC said, the standards need not dictate specific protective steps to be taken. But they “need to require that owners or operators of identified critical facilities have a plan that results in an adequate level of protection.”

FERC expects that the number of critical facilities will be relatively small. Most substations, for example, would not be deemed critical under the standards.

“We do not expect that every owner and operator of the bulk power system will have critical facilities under the reliability standard,” the commission said. “We also recognize that the industry has engaged in longstanding efforts to address the physical security of its critical facilities.”

Norris’ Concerns

Commissioner Norris issued a concurring statement expressing concerns that the expedited 90-day deadline and the commission’s ex-parte rules will inhibit the development of intelligent rules.

“I believe the order does not sufficiently justify the uniquely expedited nature of the standard development process, particularly when it will foreclose the Commission from engaging with stakeholders during that process,” Norris said.