
[Federal Register Volume 88, Number 164 (Friday, August 25, 2023)]
[Notices]
[Pages 58260-58262]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-18336]


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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. RD23-2-000]


Physical Security Technical Conference; Notice Inviting Post-
Technical Conference Comments

    On Thursday, August 10, 2023, the Federal Energy Regulatory 
Commission (Commission) and the North American Electric Reliability 
Corporation (NERC) convened a Physical Security Technical Conference to 
discuss physical security of the Bulk-Power System, including the 
adequacy of existing physical security controls, challenges, and 
solutions.
    All interested persons are invited to file post-technical 
conference comments to address issues raised during the technical 
conference identified in the Final Notice of Joint Technical Conference 
issued on August 3, 2022. For reference, the questions included in the 
Final Notice are included below, and supplemental questions appear in 
italics. Commenters need not answer all of the questions but are 
encouraged to organize responses using the numbering and order in the 
below questions. Commenters are also invited to reference material 
previously filed in this docket but are encouraged to avoid repetition 
or replication of their previous comments. Comments must be submitted 
on or before 30 days from the date of this Notice.

[[Page 58261]]

    Comments, identified by docket number, may be filed electronically 
or paper-filed. Electronic filing through https://www.ferc.gov is 
preferred. Documents must be filed in acceptable native applications 
and print-to-PDF, but not in scanned or picture format. Instructions 
are available on the Commission's website: http://www.ferc.gov/docs-filing/efiling.asp.
    Although the Commission strongly encourages electronic filing, 
documents may also be paper-filed. To paper-file, submissions sent via 
the U.S. Postal Service must be addressed to: Federal Energy Regulatory 
Commission, Office of the Secretary, 888 First Street NE, Washington, 
DC 20426. Submissions sent via any other carrier must be addressed to: 
Federal Energy Regulatory Commission, Office of the Secretary, 12225 
Wilkins Avenue, Rockville, Maryland 20852.
    For more information about this Notice, please contact:

Terrance Clingan (Technical Information), Office of Energy Reliability, 
(202) 502-8823, [email protected]
Leigh Anne Faugust (Legal Information), Office of General Counsel, 
(202) 502-6396, [email protected]

    Dated: August 21, 2023.
Debbie-Anne A. Reese,
Deputy Secretary.

Post Technical Conference Questions

    We are seeking comments on the topics discussed during the 
technical conference held on August 10, 2023, including responses to 
the questions listed in the Final Notice issued in this proceeding on 
August 3, 2023, as well as supplemental questions developed by 
Commission staff post-conference. The questions from the agenda and the 
supplemental questions are included below.

Panel 1: Effectiveness of Reliability Standard CIP-014-3

    This panel explored the facilities subject to Reliability Standard 
CIP-014-3. While the NERC report filed with the Commission did not 
recommend revising the applicability section of the Standard at this 
time, the report determined that this could change based on additional 
information. Panelists discussed whether the applicability section of 
Reliability Standard CIP-014-3 identifies the appropriate facilities to 
mitigate physical security risks to better assure reliable operation of 
the Bulk-Power System. Panelists also discussed whether additional 
type(s) of substation configurations should be studied to determine 
risks and the possible need for required protections.
    Please address the following questions:
    1. Is the applicability section of CIP-014-3 properly determining 
transmission station/substations to be assessed for instability, 
uncontrolled separation or cascading within the Interconnection? 
Specifically, are the correct facilities being assessed and what 
topology or characteristics should the applicable facilities have to be 
subject to CIP-014-3? For example, are there criteria other than those 
in Section 4.1.1 of CIP-014-3, such as connected to two vs. three other 
station/substations and exceeding the aggregated weighted value of 
3,000, changing the weighting value of the table in the applicability 
section, or including lower transmission voltages?
    2. Given the changing threat landscape, are there specific 
transmission station/substation configurations that should be included 
in the applicability section of CIP-014-3, including combinations of 
stations/substations to represent coordinated attacks on multiple 
facilities? What would they be and why?
    3. What other assessments (e.g., a TPL-001 planning assessment) may 
be used to identify an at-risk facility or group of facilities that 
should be considered for applicability under CIP-014-3? How stringent 
are those assessments? Describe any procedural differences between 
those other assessments and the CIP-014-3 R1 Risk Assessment. Should 
CIP-014-3 apply to entities other than those transmission owners to 
which 4.1.1 applies or transmission operators to which 4.1.2 applies?
    4. Should potential load loss or generation loss be considered? If 
so, why, and how would potential impact be determined (e.g., how would 
potential load loss be determined in advance of running an 
assessment?)?
    5. Should facilities that perform physical security monitoring 
functions that are not currently subject to CIP-014-3 (e.g., security 
operation centers) be covered by CIP-014-3 as well? If so, what 
criteria should be used?
    6. Are there additional studies that could be performed--either by 
industry, the ERO Enterprise, the national labs, or others--that could 
be used to determine whether there are unidentified CIP-014 
``critical'' transmission stations and transmission substations? Are 
there additional studies that would help determine whether the 
applicability section of the standard requires expansion to identify 
those transmission substations/stations that if lost or rendered 
inoperable would result in instability, uncontrolled separation or 
cascading within an Interconnection.
    7. How should extreme conditions be considered when identifying 
``critical'' transmission substations/stations such as extended extreme 
weather events or disasters such as wildfires that weaken the 
resiliency of the Bulk-Power System?

Panel 2: Minimum Level of Physical Protection

    This panel discussed the reliability goal to be achieved and based 
on that goal, what, if any, mandatory minimum resiliency or security 
protections should be required against facility attacks, e.g., site 
hardening, ballistic protection, etc. This panel discussed the scope of 
reliability, resilience, and security measures that are inclusive of a 
robust, effective, and risk-informed approach to reducing physical 
security risks. The panel also considered whether any minimum 
protections should be tiered and discuss the appropriate criteria for a 
tiered approach.
    Please address the following questions:
    1. What is our reliability goal? What are we protecting against to 
ensure grid reliability beyond what is required in the current 
standards?
    a. What are the specific physical security threats (both current 
and emerging) to all stations/substations on the bulk electric system?
    b. As threats are continually evolving, how can we identify those 
specific threats?
    c. How do threats vary across all stations/substations on the bulk 
electric system? How would defenses against those threats vary? To what 
extent should simultaneous attacks at multiple sites be considered?
    2. Do we need mandatory minimum protections? If so, what should 
they be?
    a. Should there be flexible criteria or a bright line?
    b. Should minimum protections be tiered (i.e., stations/substations 
receive varying levels of protection according to their importance to 
the grid)? How should importance be quantified for these protections?
    c. Should minimum protections be based on preventing instability, 
uncontrolled separation, or cascading or preventing loss of service to 
customers (e.g., as in Moore County, NC)? If minimum protections were 
to be based on something other than the instability, uncontrolled 
separation, or cascading, what burden would that have on various 
registered entities? If the focus is on loss of service, is it 
necessary to have state and local jurisdictions involved to

[[Page 58262]]

implement a minimum set of protections?
    d. In what areas should any minimum protections be focused?
    i. Detection?
    ii. Assessment?
    iii. Response?
    3. To what extent would minimum protections help mitigate the 
likelihood and/or reliability impact of simultaneous, multi-site 
attacks?
    4. To what extent would the placement of basic security-related 
data recording devices and associated equipment at stations/substations 
(varying based on the criticality of the stations/substations as 
determined by the transmission owner) to allow for an assessment of 
damage and the collection of evidence in the event of an attack provide 
any security benefit? Such devices and equipment could possibly provide 
alarms in real time to operating centers or merely be reviewed on 
demand when a singular disturbance alarm is sent to an operating 
center.
    5. Are there basic levels of protection that all Bulk-Power System 
facilities use, such as fencing? Would minimum improvements to these 
protections, such as adding better security requirements to the present 
public safety requirements, better deter attacks?
    6. Given the increasing number and severity of physical security 
threats and perpetrated attacks:
    i. Should transmission owners annually evaluate evolving physical 
threats and implement corresponding security measures for CIP-014 
critical facilities?
    ii. What criteria should be considered in evaluating the impact of 
evolving threats and appropriate protections (e.g., criticality of 
load, likely duration of outage, location of station/substation)?
    iii. How should transmission owners prioritize security measures 
for facilities that are not CIP-014 critical facilities? For example, 
should transmission owners document and implement a tiered approach to 
protecting bulk electric system (i.e., 100 kV and above) stations and 
substations based on criteria characterizing the level of impact 
(high(i.e., CIP-014 critical), medium, or low), similar to CIP-002-
5.1a?

Panel 3: Best Practices and Operational Preparedness

    This panel discussed physical security best practices for 
prevention, protection, response, and recovery. The discussion included 
asset management strategies to prepare, incident training preparedness 
and response, and research and development needs.
    Please address the following questions:
    1. What is the physical security threat landscape for each of your 
companies? What best practices have been implemented to mitigate the 
risks and vulnerabilities of physical attacks on energy infrastructure?
    2. What asset management and preparedness best practices have your 
member companies implemented to prevent, protect against, respond to, 
and recover from physical attacks on their energy infrastructure?
    3. What research and development efforts are underway or needed for 
understanding and mitigating physical security risks to critical energy 
electrical infrastructure?
    4. What research and development efforts, including the development 
of tools, would you like to see the National Labs undertake to assist 
your companies in addressing physical threats to your critical 
electrical infrastructure?
    5. What do you need or would like to see from the energy industry 
to improve your ability and accuracy in addressing physical security 
risks to critical energy electrical infrastructure?
    6. What best practices are in place to accelerate electric utility 
situational awareness of an incident and to involve local jurisdiction 
responders?
    7. What can the federal and state regulators do to assist the 
energy industry in improving their physical security posture?
    8. What training improvements can NERC and the Regional Entities 
implement to system operators to aid in real-time identification and 
recovery procedures from physical attacks?
    9. What changes could be made to improve information sharing 
between the federal government and industry?
    10. How do these best practices comport with the objectives of CIP-
014-3?

Panel 4: Grid Planning To Respond to and Recover From Physical and 
Cyber Security Threats and Potential Obstacles

    This panel explored planning to respond to and recovery from 
physical and cyber security threats and potential obstacles to 
developing and implementing such plans. This discussion focused on how 
best to integrate cyber and physical security with engineering, 
particularly in the planning phase. The panel discussed whether 
critical stations could be reduced through best practices and how to 
determine whether to mitigate the risk of a critical station or protect 
it. Finally, the panel considered the implications of the changing 
resource mix on vulnerability of the grid and its resilience to 
disruptions.
    Please address the following questions:
    1. How can cyber and physical security be integrated with 
engineering, particularly planning? What aspects of cyber and physical 
security need to be incorporated into the transmission planning 
process?
    2. What modifications could be made to TPL-001 to bring in broader 
attack focus (e.g., coordinated attack)? What sensitivities or examined 
contingencies might help identify vulnerabilities to grid attacks?
    3. Currently, if a CIP-014-3 R1 assessment deems a transmission 
station/substation as ``critical'' that station/substation must be 
physically protected. Are there best practices for reconfiguring 
facilities so as to reduce the criticality of stations/substations?
    4. When prioritizing resources, how should entities determine which 
``critical'' stations/substations to remove from the list and which to 
protect? If the project is extensive and may have a long lead time to 
construct, to what degree does the station/substation need to be 
protected during the interim period?
    5. How will the development of the grid to accommodate the 
interconnection of future renewable generation affect the resilience of 
the grid to attack? Will the presence of future additional renewable 
generation itself add to or detract from the resilience of the grid to 
physical attack?
    6. What are the obstacles to developing a more resilient grid? What 
strategies can be used to address these obstacles?
    a. Cost?
    b. Siting?
    c. Regulatory Barriers?
    d. Staffing/training?
    7. How can transmission owners better work with state commissions 
on physical security? For example, are there opportunities to better 
work together as part of approval processes for projects (e.g., 
applications for certificates of public convenience and necessity)?
    8. How can security protections be better integrated into the 
planning, engineering, and construction of projects that improve the 
security of the grid and overall performance and resilience, while 
keeping critical energy infrastructure information from being 
inappropriately released?

[FR Doc. 2023-18336 Filed 8-24-23; 8:45 am]
BILLING CODE 6717-01-P


