FERC Approves Version 5 CIP Reliability Standards, Rejects Key Reforms

On November 22, the Federal Energy Regulatory Commission (FERC or Commission) issued Order No. 791,[1] approving comprehensive revisions to the Critical Infrastructure Protection (CIP) Reliability Standards. The revisions were recently proposed by the North American Electric Reliability Corporation (NERC) to address many of the concerns regarding CIP compliance that have arisen over the last few years as well as to close out the remaining Commission directives ordering changes to the CIP Reliability Standards. However, although the Commission approved the substantive changes to the technical cybersecurity protection requirements contained in the proposed CIP Reliability Standards, the Commission rejected key reforms proposed by NERC, namely (a) NERC's proposal to end "zero tolerance" enforcement of the CIP