NERC Submits Wide-Area Analysis On Use Of Technical Feasibility Exceptions For CIP Standards

On September 28, 2015, the North American Electric Reliability Corporation ("NERC") submitted to FERC its annual analysis on the use of Technical Feasibility Exceptions ("TFEs"). TFEs are exceptions from strict compliance with NERC Critical Infrastructure Protection ("CIP") Reliability Standards that Registered Entities may apply for, pursuant to a process established in the NERC Rules of Procedure.

On January 18, 2008, the Commission issued Order No. 706, in which it approved eight CIP Reliability Standards, and, among other things, directed NERC to develop a procedural mechanism by which entities could seek TFEs. The Commission also required NERC to submit an annual report that provides a wide-area analysis of the use of TFEs, and their associated impact on Bulk-Power System reliability.