Federal Energy Regulatory Commission (FERC) Filings
Notice of Penalty Dockets for Compliance Enforcement with NERC Reliability Standards:
Notice of Proposed Rulemaking for the Grid Resiliency Pricing Rule:
Testimony before FERC:
Resilient Societies initiatives for improved electric grid reliability standards:
FERC Docket RM15-14 on Revised Critical Infrastructure Protection Reliability Standards, which would establish requirements for cybersecurity protection of communications networks for the Bulk Power System and also require supply chain protection:
FERC Docket RM15-25 on the U.S. Government gaining access to three North American Electric Reliability Corporation databases containing electric utility records of grid reliability and security incidents: (1) the Transmission Availability Data System (TADS), (2) the Generator Availability Data System (GADS), and (3) the protection system misoperations database.
FERC Order 791, which directed NERC to provide definitions for critical cybersecurity-related terms:
FERC Docket RM15-11 on NERC Reliability Standard TPL-007-001, which sets a standard for Geomagnetic Disturbance (GMD) protection in high-voltage transformers:
FERC Docket RM14-1-000 for Notice of Proposed Rulemaking on Geomagnetic Disturbance Operating Procedures:
FERC Docket AD12-13-000 on setting a standard for Geomagnetic Disturbance protection:
FERC Docket RM12-22-000 for Notice of Proposed Rulemaking on Geomagnetic Disturbance:
FERC Grid Assurance Docket EL-15-76, which proposes stocking and positioning of spare transformers:
FERC Docket RD14-6-000 for NERC Physical Security Standard to Protect Critical Grid Assets. (FERC placed our letter to Senate on FERC public docket on its own initiative; we did not submit letter to the docket.):
FERC Docket RM14-15-000 for NERC Physical Security Standard CIP-14-1 to Protect Critical Grid Assets:
- Comments on Docket No. AD19-18-000 for Transparency in Enforcement of Reliability Standards; October 28, 2019
- Motion for Public Hearing on Transparency in Enforcement of Reliability Standards; October 23, 2019
- Reply Comments to Trade Associations on Docket NP19-4-00 (Duke Energy); April 24, 2019
- Comments on Docket NP19-4-00 (Duke Energy); March 26, 2019
- Freedom of Information Act Request for Withheld Notices of Penalties for Vegetation Management; April 22, 2019
Notice of Proposed Rulemaking for the Grid Resiliency Pricing Rule:
- Request for Rehearing on Docket RM-1-000; February 7, 2018
- Reply Comments on Docket RM18-1-000; November 8, 2017
- Comments on Docket RM18-1-000; October 24, 2017
Testimony before FERC:
- Reliability Technical Conference for Docket AD17-8-000; June 22, 2017
- Reliability Technical Conference for Docket AD16-15-000; June 1, 2016
- Geomagnetic Disturbance Technical Conference for Docket RM15-11-000; March 1, 2016
Resilient Societies initiatives for improved electric grid reliability standards:
- Petition for Rulemaking for Enhanced Malware Standard; Jan 13, 2017
- Comments on Docket RM18-2-000, Cyber Security Incident Reporting Reliability Standards; Feb 26, 2018
FERC Docket RM15-14 on Revised Critical Infrastructure Protection Reliability Standards, which would establish requirements for cybersecurity protection of communications networks for the Bulk Power System and also require supply chain protection:
- Joint Request and Motion to Reopen Evidentiary Record on FERC Order 822 for Docket RM15-14-000; Mar 29, 2016
- Resilient Societies Request for Rehearing on FERC Order 822 for Docket RM15-14-000, Feb 22, 2016
- Resilient Societies Briefing on Exercise of FERC Authority for Cybersecurity of the North American Electric Grid; Jan 28-29, 2016
- Resilient Societies Comments on proposed modifications to NERC Reliability Standard CIP-006-6; Sep 21, 2015
- Isologic and Resilient Societies Comments on proposed modifications to NERC Reliability Standard CIP-006-6; Sep 21, 2015
FERC Docket RM15-25 on the U.S. Government gaining access to three North American Electric Reliability Corporation databases containing electric utility records of grid reliability and security incidents: (1) the Transmission Availability Data System (TADS), (2) the Generator Availability Data System (GADS), and (3) the protection system misoperations database.
FERC Order 791, which directed NERC to provide definitions for critical cybersecurity-related terms:
FERC Docket RM15-11 on NERC Reliability Standard TPL-007-001, which sets a standard for Geomagnetic Disturbance (GMD) protection in high-voltage transformers:
- Request for Rehearing of FERC Order 830, Reliability Standard for Geomagnetic Disturbance Events, Oct 24, 2017
- Resilient Societies Supplemental Comments on Cost Recovery for Geomagnetic Disturbance Mitigation; Mar 15, 2016
- Resilient Societies Testimony at March 1, 2016 FERC Geomagnetic Disturbance Technical Conference; Feb 23, 2016
- Resilient Societies Comments on FERC Notice of Proposed Rulemaking on NERC Standard TPL-007-1; Aug 10, 2015
- Resilient Societies Petition to FERC on Inadequacy of Quality Control and Non-Use of Scientific Method; Sep 10, 2015
- Resilient Societies Petition to FERC on Los Alamos National Laboratory Report on NERC Standard TPL-007-1; Sep 29, 2015
- Resilient Societies Comments to FERC on Los Alamos National Laboratory Report on NERC Standard TPL-007-1; Oct 22, 2015
FERC Docket RM14-1-000 for Notice of Proposed Rulemaking on Geomagnetic Disturbance Operating Procedures:
- Resilient Societies Supplemental Information on Geomagnetically Induced Current (GIC) Monitors; August 18, 2014
- Resilient Societies Comments on RM14-1; March 24, 2014
- Resilient Societies Request for rehearing and remand on FERC's final decision; June 21, 2014
FERC Docket AD12-13-000 on setting a standard for Geomagnetic Disturbance protection:
- AD12-13-000_Resilient Societies Commonsense appeal to the FERC Commissioners for action on a regulatory standard for Solar Storm Protection; May 21, 2012
- AD12-13-000_Resilient Societies Research paper on GMD-induced damage at Seabrook Nuclear Power Station; Apr 25, 2012
FERC Docket RM12-22-000 for Notice of Proposed Rulemaking on Geomagnetic Disturbance:
- Resilient Societies Supplemental Comments on RM12-22 regarding inadequate standard-setting procedure; May 14, 2013
- Resilient Societies Supplemental Comments on RM-12-22 regarding GMD-induced damaged to Central Maine Power; May 1, 2013
- Resilient Societies Supplemental Comments on Docket RM-12-22 regarding GMD Operating Procedures; Apr 1, 2013
- Resilient Societies Reply to NERC Comments on RM-12-22; Jan 11,2013
- Resilient Societies Comments on FERC Docket RM12-22; Dec 24, 2012
FERC Grid Assurance Docket EL-15-76, which proposes stocking and positioning of spare transformers:
FERC Docket RD14-6-000 for NERC Physical Security Standard to Protect Critical Grid Assets. (FERC placed our letter to Senate on FERC public docket on its own initiative; we did not submit letter to the docket.):
FERC Docket RM14-15-000 for NERC Physical Security Standard CIP-14-1 to Protect Critical Grid Assets: