Thursday, July 26, 2012

The State of the States and Smart Grid Security

Readers, working your way through this comprehensive yet non alarmist EPIC PIECE of Smart Grid security journalism will take some time, because author and former NH PUC commissioner Nancy Brockway has done her homework and then some.

And unlike some unschooled energy security bloggers I know, she knows all the business angles. To whit:
Utilities might argue that they need pre-approval and current recovery of cybersecurity costs. Utilities and their smart grid industry partners sometimes claim that without such cost recovery, a utility will lack the ability and resources to pursue cybersecurity with vigor, presumably because in and of themselves, cybersecurity investments don’t generate revenue. However, the industry has it backwards.
See what I mean? OK, here's the cybersecurity funding smackdown:
If a utility executive says the firm won’t vigorously pursue cybersecurity absent a tracker to recover its costs outside the normal ratemaking treatment, the utility is signalling that it might not have fully embraced the goal of such security. And a utility that tries to reassure the commission that such guaranteed revenues can be clawed back on a later finding of imprudence might be hoping the commissioners are naive about how prudence reviews work.
Hold on; one more volley and it's over:
There’s a huge difference between pre-approving and providing extra-rate-case recovery of utility investments in cybersecurity, and making it clear that the commission understands the need to change out obsolete equipment and technology, beef up staff, and make investments to protect the grid. But if a utility cares so little about cybersecurity that it won’t pursue the smart grid or the cybersecurity component of the smart grid absent guaranteed, dollar-for-dollar, few-questions-asked revenues awarded outside of normal cost recovery, this should be a red flag to the commission about letting that utility install the connectivity inherent in the smart grid.
About the only point Ms. Brockway seems to have missed re: State actions is the recent publication of a pretty decent and helpful guide by NARUC, which we posted on earlier and you can view HERE. Didn't seem like you could comment on the article, but I'll be very interested to hear what folks make of her positions on these matters, particularly the funding aspects.