FERC and NERC: Who Blinks First on Bright-Lines?

This post continues a series where we try to get a fix on where the next versions of the CIPs are going, and exactly when they're coming (see previous posts on this topic from March and April of this year).

You know, if there was some sex or violence, or even a little Ian flemming-esque international intrigue involved, the quest for the next version of the NERC CIPS might merit its own slot on prime time. As it is, however, it can best be called a regulatory reality show.

As this new open letter (registration required) from security consultancy Matrikon reveals, the producer, FERC, seems to be tiring of its wayward plot and may begin inserting a script more to its own liking.

While a full accounting of recent events gets quickly quite complicated, much of the kerfuffle centers on the so-called "bright line criteria" (aka, the rules) used to determine which additional electrical generation and transmission assets will get CIP scrutiny when the long awaited version 4 finally arrives.

I'm over simplifying things, of course, but in a nutshell, FERC wants more bulk power assets monitored, while utilities want fewer. And poor NERC is caught in between, taking too long, and is hamstrung by the rules its actions.

The open letter paints a pretty good picture of this dynamic, and while never claiming certain knowledge of how things will ultimately play out, I think this paragraph imparts the tension of the present impass:

Earlier in the NERC/FERC relationship, FERC would have simply disapproved Version 4 and sent it back to NERC to rewrite, submit for new comments and ballot(s), redo the survey with whatever changes came out of the balloting and then make a new filing to FERC. This would probably take close to a year. Our guess is this will not happen. FERC has been losing patience with the NERC standards process for a while, and they (and members of Congress) have repeatedly stated that the security of the BES is at risk given the current coverage of critical assets in NERC CIP.

Seems like the ball is in FERC's court. All we can do is stay tuned. And of course, if I've misrepresented the current situation in some way, please let me know so I can help get the right knowledge out there.