UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
Internal Network Security Monitoring for High and Medium Impact Bulk Electric System Cyber Systems } Docket No. RM22-3-000
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
EPSA filed comments on the Federal Energy Regulatory Commission (FERC)’s Notice of Proposed Rulemaking on Internal Network Security Monitoring (INSM) for high- and medium-impact Bulk Electric System (BES) Cyber Systems (RM22-3). EPSA’s comments address a host of INSM issues as they impact independent power producers (IPPs), while echoing the arguments of joint comments filed by a number of electric trade associations (which EPSA also signed.)
EPSA members take very seriously the cyber and physical security of their operations and the grid. Ensuring that all cyber and physical security considerations are fully addressed is central to the reliable operations of all participants in the delivery of electricity to consumers, including IPPs and competitive power suppliers who rely on capacity, energy, and ancillary market revenues to support operations and safety activities.
EPSA also joined comments developed and submitted concurrently by a coalition of electricity trade associations, including the Edison Electric Institute, the American Public Power Association, the Large Public Power Council, and the National Rural Electric Cooperative Association, together “The Joint Trade Associations.” View here