Comments re: FERC Notice of Proposed Rulemaking, Reliability Standard for Geomagnetic Disturbance Operations, Docket No. RM14-1-000

March 24, 2014
Ms. Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
Re:      FERC Notice of Proposed Rulemaking, Reliability Standard for Geomagnetic Disturbance Operations, Docket No. RM14-1-000
Dear Ms. Bose:

The Institute for 21st Century Energy (the “Energy Institute”), an affiliate of the U.S. Chamber of Commerce, the world’s largest business federation representing the interests of more than three million businesses and organizations of every size, sector and region, submits these comments in response to the January 16, 2014, issuance by the Federal Energy Regulatory Commission (“Commission”) of a Notice of Proposed Rulemaking issued in Docket No. RM14-1-000 that proposes to approve a reliability standard aimed at mitigating the effects of a geomagnetic disturbance on the Bulk-Power System (the “GMD NOPR”).  The Energy Institute supports both the process and the product related to Reliability Standard EOP-010-1 (Geomagnetic Disturbance Operations), and thus supports the standard’s proposed adoption.

The actual impact that a significant geomagnetic disturbance – or GMD event – could have on the electric grid and the components thereof, either from a solar flare or alternate triggering device, remains largely conceptual.  While some equipment suppliers claim to have the silver bullet necessary to protect against these types of events, it is unclear whether these proposed “solutions” would serve to insulate the grid or instead make aspects of the grid more vulnerable to the forces resulting from a GMD event.  Nevertheless, consistent with the Energy Institute’s recommendation within its recently-released “Energy Works for US” policy platform, it is essential that the industry, in cooperation with relevant governmental entities, develop a greater understanding and associated expertise regarding the potential vulnerabilities that may exist within the Bulk-Power System to a significant GMD event.  Attached to these comments please find our “two pager” document that summarizes the Energy Works for US chapter, and associated recommendations, on physical and cyber risks to energy infrastructure.

The Energy Institute believes that the GMD NOPR moves the needle in the correct direction by proposing to adopt a standard that was developed through the stakeholder standards development process administered by the North American Electric Reliability Corporation (NERC).  As a result, the standards reflect informative outreach to industry and the technical expertise residing therein, and result in a standard that is purposely not prescriptive in nature.  Rather, the standard appropriately provides individual owners and operators of covered infrastructure the latitude to determine the operating processes and procedures that work best for their specific situation and system in the face of a GMD event.

The GMD NOPR is also commendable because it supports information sharing with respect to the requirement that reliability coordinators disseminate space weather information.  This approach is consistent with the information sharing recommendations that the Energy Institute has also advocated with respect to the strategies that should be implemented to protect the electric grid from malicious cyber intrusions.  While cyber security differs in certain aspects as compared to the threats posed by a GMD event, the benefits that can accrue from the sharing of actionable information, among the right people, in a timely manner, holds true in each domain.  The GMD NOPR moves in this direction, even though it involves the dissemination of publicly available information to the system operators and reliability coordinators that would need to take protective action with Bulk Power System equipment during a GMD event.

The GMD NOPR appropriately proposes to approve a non-prescriptive standard that provides for the flexibility that is necessary to enable electric system owners and operators to best protect the unique equipment and system configurations that exist across the interconnected electric grid.  The Commission should be commended for proposing to approve the adoption of Standard EOP-010-1, because it will enhance the reliability of the Bulk-Power System.

We appreciate your consideration of the Energy Institute’s comments, herein, as part of the above-captioned rulemaking process.


Karen A. Harbert