as every device within the system is documented as to its capability for meeting that requirement. If this is not the intent of the SDT, this issue must be addressed along with the definitions, because it is at this fundamental level that the Standards may or may not be applicable. [2] NSRF recommends the addition of a definition for a “BES to be described as: Site” registered entity-owned geographic location that: (1) “A performs the functional obligations of the Reliability Coordinator, Balancing Authority, Generator Operator, Generator Owner, Interchange Coordinator, Reliability Coordinator, Transmission Operator, or Transmission Owner, including Control Centers, Backup Control Centers and associated data centers that support those functional obligations, and(2) contains UFLS or UVLS Systems that are part of a Load shedding program and Load-Serving Entity functional obligation, or(3) provides the protection or restoration of the BES while performing the functional obligations of Distribution Provider, or (4) provides Blackstart Resources, (and) that if rendered unavailable, degraded, or misused would, within 15 minutes of its required operation, mis-operation, or non-operation, adversely impact the reliability of the BES.” Associated Electric [BES Cyber Asset, Definitions, p 1REPLACE: and is used for”WITH: and is only “, “, Cooperative, Inc. (NCR01177, used for”RATIONALE: AECI agrees with other commenters on the need for this JRO00088) clarification.] NYISO o BES Cyber Asset definition from "it is directly connected to a Cyber Asset within an ESP" to "it is directly connected to a network, or to a Cyber Asset within an ESP" Alliant Energy Alliant Energy voted on this list of definitions as we believe it is in fundamental “No” conflict with the rest of the Standards. Proposed definitions herein should be considered within the context of the requirements, as well, due to considerable dependency between the proposed definitions and the proposed language changes throughout the rest of the Standards. Alliant Energy supports the MRO NSRF comments, as well.[1]Alliant Energy’s recommendations on these definitions are predicated by our position that CIP-002-5 is fundamentally flawed, and the proposed methodology prescribed by Requirement 1 is in direct conflict with the structure of the definition for BES Cyber Asset and BES Cyber System. More specifically, the impact
as every device within the system is documented as to its capability for meeting that requirement. If this is not the intent of the SDT, this issue must be addressed along with the definitions, because it is at this fundamental level that the Standards may or may not be applicable. [2] NSRF recommends the addition of a definition for a “BES Site” to be described as: “A registered entity-owned geographic location that: (1) performs the functional obligations of the Reliability Coordinator, Balancing Authority, Generator Operator, Generator Owner, Interchange Coordinator, Reliability Coordinator, Transmission Operator, or Transmission Owner, including Control Centers, Backup Control Centers and associated data centers that support those functional obligations, and(2) contains UFLS or UVLS Systems that are part of a Load shedding program and Load-Serving Entity functional obligation, or(3) provides the protection or restoration of the BES while performing the functional obligations of Distribution Provider, or (4) provides Blackstart Resources, (and) that if rendered unavailable, degraded, or misused would, within 15 minutes of its required operation, mis-operation, or non-operation, adversely impact the reliability of the BES.” Associated Electric Cooperative, Inc. (NCR01177, JRO00088) [BES Cyber Asset, Definitions, p 1REPLACE: “, and is used for”WITH: “, and is only used for”RATIONALE: AECI agrees with other commenters on the need for this clarification.] NYISO o BES Cyber Asset definition from "it is directly connected to a Cyber Asset within an ESP" to "it is directly connected to a network, or to a Cyber Asset within an ESP" Alliant Energy Alliant Energy voted “No” on this list of definitions as we believe it is in fundamental conflict with the rest of the Standards. Proposed definitions herein should be considered within the context of the requirements, as well, due to considerable dependency between the proposed definitions and the proposed language changes throughout the rest of the Standards. Alliant Energy supports the MRO NSRF comments, as well.[1]Alliant Energy’s recommendations on these definitions are predicated by our position that CIP-002-5 is fundamentally flawed, and the proposed methodology prescribed by Requirement 1 is in direct conflict with the structure of the definition for BES Cyber Asset and BES Cyber System. More specifically, the impact
Comment_Report_D_052212.docx