Venue: Federal Energy Regulatory Commission
Date: September 20, 2023
Proceeding: August 10, 2023 FERC/NERC Physical Security Technical Conference (RD23-2-000)
Summary: These comments support continued examination of the effectiveness of CIP-014-3 and highlight that any additional NERC action should be performance-based in nature. Given the site and terrain specific challenges that are associated with individual substations, it is critical that utilities be given flexibility to protect their equipment in ways that are most effective for their circumstances, in terms of cost, performance, and results.
