FERC-725B, [NOPR in RM11-11] Mandatory Reliability Standards for Critical Infrastructure Protection

Forms and Documents

Document Name	Status
SuppStatement_10_31_11.doc Supporting Statement A	2011-10-31
news release20110915-4001.doc Supplementary Document	2011-09-15
Statutes and Regs for Reliability.doc Supplementary Document	2011-04-08

IC Document Collections

IC ID	Document Title	Status
181478	FERC-725B, Mandatory Reliability Standards for Critical Infrastructure Protection	Modified

ICR Details

OMB Control No: 1902-0248	ICR Reference No: 201109-1902-006
Status: Historical Inactive	Previous ICR Reference No: 201104-1902-001
Agency/Subagency: FERC	Agency Tracking No: FERC-725B
Title: FERC-725B, [NOPR in RM11-11] Mandatory Reliability Standards for Critical Infrastructure Protection
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Comment filed on proposed rule and continue	Conclusion Date: 12/08/2011
	Date Received in OIRA: 09/28/2011
Terms of Clearance: Terms of the previous clearance remain in effect. The agency intends to issue a final rule in response to comments addressing the proposed amendments. When the agency resubmits on that rulemaking action, it is strongly recommended that it substantively address public comments and any related burden estimate changes in its submission.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2014	36 Months From Approved	09/30/2014
Responses	1,501	0	1,501
Time Burden (Hours)	819,840	0	819,840
Cost Burden (Dollars)	5,261	0	5,261

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Abstract: The CIP Reliability Standards are necessary to support the reliable operation of the Bulk-Power System. In this NOPR in RM11-11, FERC proposes to approve Version 4 of the CIP Reliability Standards, CIP-002-4 through CIP-009-4. The proposed Version 4 CIP Reliability Standards were developed and submitted by NERC to FERC for approval. In general, the CIP Reliability Standards provide a cybersecurity framework for the identification and protection of Critical Cyber Assets to support the reliable operation of the Bulk-Power System. In particular, the Version 4 CIP Reliability Standards propose to modify CIP-002-4 to include "bright line" criteria for the identification of Critical Assets, in lieu of the currently-required risk-based assessment methodology that is developed and applied by registered entities. In addition, NERC developed proposed conforming modifications to the remaining CIP Reliability Standards, CIP-003-4 through CIP-009-4. FERC proposes to approve Version 4 of the CIP Reliability Standards, the Violation Risk Factors (VRFs) and the Violation Severity Levels (VSLs) with modifications, the associated implementation plan, and the effective date for Version 4 CIP Reliability Standards as proposed by NERC. The Commission also proposes to approve the retirement of the currently effective Version 3 CIP Reliability Standards, CIP-002-3 to CIP-009-3. While FERC proposes to approve the Version 4 CIP Standards, like NERC, the Commission recognizes that the Version 4 CIP Standards represent an "interim step" to addressing all of the outstanding directives set forth in Order No. 706. The Commission believes that the electric industry, through the NERC standards development process, should continue to develop an approach to cybersecurity that is meaningful and comprehensive to assure that the nation's electric grid is capable of withstanding a Cybersecurity Incident. FERC expects NERC will continue to improve the CIP Reliability Standards and to address all outstanding directives in Order No. 706. How is the information used? Under the CIP Reliability Standards a registered entity is not required to "report" to the Commission, ERO or the Regional Entities, the various policies, plans, programs and procedures to demonstrate compliance with the CIP Reliability Standards. However, a registered entity is required to "produce" the documented policies, plans, programs and procedures during a periodic compliance audit or spot check for example to demonstrate compliance with the CIP Reliability Standards. Who uses the information? The registered entity utilizes the information during a periodic audit to demonstrate compliance with the CIP Reliability Standards. Why is the information collected? The registered entities purpose in documenting policies, plans, programs and procedures is to clearly establish for the auditors how the CIP Reliability Standards are being followed. What are the consequences of not collecting the information? Without this documentation, the compliance enforcement authority would have difficulty in verifying compliance to the CIP Reliability Standards. Without the ability to verify compliance to the CIP Reliability Standards, serious breaches in cybersecurity could potentially compromise the reliable operation of the Bulk-Power System.

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Authorizing Statute(s): PL: Pub.L. 109 - 58 1211, Title XII, Subtitle A Name of Law: Energy Policy Act of 2005
   US Code: 18 USC 824o Name of Law: Federal Power Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
1902-AE41	Proposed rulemaking	76 FR 58730	09/22/2011

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
FERC-725B, Mandatory Reliability Standards for Critical Infrastructure Protection

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Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: As stated in the press release, FERC "took steps to support continued transmission system reliability by proposing revisions to eight critical infrastructure protection reliability standards that include a new method of identifying cyber assets that are critical to the nation's bulk power grid. The proposed "Version 4" CIP standards are an interim step, FERC said in directing the electric industry and the North American Electric Reliability Corp. (NERC) to continue developing a comprehensive approach to assure the grid can withstand a cyber security incident. NERC is the Commission-certified electric reliability organization responsible for developing and enforcing mandatory reliability standards. The new standard would replace the existing risk-based assessment methodology for identifying critical assets with 17 uniform "bright line" criteria, making the process more consistent and clear by limiting discretion in the identification of such assets."

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Annual Cost to Federal Government: $1,575

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 09/28/2011

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