Today’s LiveWire Spotlight examines the recently posted revisions to the Rules of Procedure (ROP) arising from FERC’s most recent five-year analysis of NERC’s performance as the Electric Reliability Organization. FERC identified two opportunities for improvement:
- The strategic direction of the E-ISAC has evolved opaquely as it transitions to the DHS’ multi-infrastructure cyber security framework.
- The even-handed application of NERC’s sanction guidelines in Appendix 4B of their Rules of procedure is impossible to assess.
The proposed ROP updates to clarify NERC’s infrastructure security program and their practices on levying fines for standards’ violations have been posted for a 45-day review period. Comments should be submitted to ROPcomments@nerc.net by July 10, 2020.