Hogan Lovells' Energy Alert: FERC proposes new critical infrastructure protection standards (agreeing to go directly from Version 3 to Version 5)
22 April 2013Energy Alert
On April 18, 2013, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR) to approve, subject to certain modifications, Version 5 of the Critical Infrastructure Protection Reliability Standards (CIP Standards) proposed by the North American Electric Reliability Corporation (NERC). Version 5 of the CIP Standards contains new requirements that address cybersecurity controls and expand the scope of systems subject to the requirements. In light of this proposal, FERC is proposing to skip the implementation of Version 4 of the CIP Standards entirely and move straight to implementing Version 5. Version 4 of the standards was approved only last year and was scheduled to go into effect in April 2014. Comments on the NOPR will be due 60 days after publication in the Federal Register, likely around June 20, 2013.