Reliability Standard CIP-014-3

CIP-014-3 — Physical Security
A. Introduction
1.

Title:

Physical Security

2.

Number:

CIP-014-3

3.

Purpose:

To identify and protect Transmission stations and Transmission
substations, and their associated primary control centers, that if
rendered inoperable or damaged as a result of a physical attack could
result in instability, uncontrolled separation, or Cascading within an
Interconnection.

4.

Applicability:
4.1. Functional Entities:
4.1.1 Transmission Owner that owns a Transmission station or Transmission
substation that meets any of the following criteria:
4.1.1.1 Transmission Facilities operated at 500 kV or higher. For the purpose
of this criterion, the collector bus for a generation plant is not
considered a Transmission Facility, but is part of the generation
interconnection Facility.
4.1.1.2 Transmission Facilities that are operating between 200 kV and 499 kV
at a single station or substation, where the station or substation is
connected at 200 kV or higher voltages to three or more other
Transmission stations or substations and has an "aggregate weighted
value" exceeding 3000 according to the table below. The "aggregate
weighted value" for a single station or substation is determined by
summing the "weight value per line" shown in the table below for
each incoming and each outgoing BES Transmission Line that is
connected to another Transmission station or substation. For the
purpose of this criterion, the collector bus for a generation plant is
not considered a Transmission Facility, but is part of the generation
interconnection Facility.
Voltage Value of a Line

Weight Value per Line

less than 200 kV (not
applicable)

(not applicable)

200 kV to 299 kV

700

300 kV to 499 kV

1300

500 kV and above

0

4.1.1.3 Transmission Facilities at a single station or substation location that
are identified by its Reliability Coordinator, Planning Coordinator, or

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CIP-014-3 — Physical Security
Transmission Planner as critical to the derivation of Interconnection
Reliability Operating Limits (IROLs) and their associated
contingencies.
4.1.1.4 Transmission Facilities identified as essential to meeting Nuclear Plant
Interface Requirements.
4.1.2 Transmission Operator.
Exemption: Facilities in a “protected area,” as defined in 10 C.F.R. § 73.2, within
the scope of a security plan approved or accepted by the Nuclear Regulatory
Commission are not subject to this Standard; or, Facilities within the scope of a
security plan approved or accepted by the Canadian Nuclear Safety Commission
are not subject to this Standard.
5.

Effective Dates:
See Implementation Plan for CIP-014-2.

6.

Background:
This Reliability Standard addresses the directives from the FERC order issued March 7,
2014, Reliability Standards for Physical Security Measures, 146 FERC ¶ 61,166 (2014),
which required NERC to develop a physical security reliability standard(s) to identify
and protect facilities that if rendered inoperable or damaged could result in
instability, uncontrolled separation, or Cascading within an Interconnection.

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CIP-014-3 — Physical Security
B. Requirements and Measures
R1. Each Transmission Owner shall perform an initial risk assessment and subsequent risk
assessments of its Transmission stations and Transmission substations (existing and
planned to be in service within 24 months) that meet the criteria specified in
Applicability Section 4.1.1. The initial and subsequent risk assessments shall consist of
a transmission analysis or transmission analyses designed to identify the Transmission
station(s) and Transmission substation(s) that if rendered inoperable or damaged
could result in instability, uncontrolled separation, or Cascading within an
Interconnection. [VRF: High; Time-Horizon: Long-term Planning]
1.1. Subsequent risk assessments shall be performed:
• At least once every 30 calendar months for a Transmission Owner that has
identified in its previous risk assessment (as verified according to
Requirement R2) one or more Transmission stations or Transmission
substations that if rendered inoperable or damaged could result in instability,
uncontrolled separation, or Cascading within an Interconnection; or
• At least once every 60 calendar months for a Transmission Owner that has not
identified in its previous risk assessment (as verified according to
Requirement R2) any Transmission stations or Transmission substations that if
rendered inoperable or damaged could result in instability, uncontrolled
separation, or Cascading within an Interconnection.
1.2. The Transmission Owner shall identify the primary control center that
operationally controls each Transmission station or Transmission substation
identified in the Requirement R1 risk assessment.
M1. Examples of acceptable evidence may include, but are not limited to, dated written or
electronic documentation of the risk assessment of its Transmission stations and
Transmission substations (existing and planned to be in service within 24 months) that
meet the criteria in Applicability Section 4.1.1 as specified in Requirement R1.
Additionally, examples of acceptable evidence may include, but are not limited to,
dated written or electronic documentation of the identification of the primary control
center that operationally controls each Transmission station or Transmission
substation identified in the Requirement R1 risk assessment as specified in
Requirement R1, Part 1.2.
R2. Each Transmission Owner shall have an unaffiliated third party verify the risk
assessment performed under Requirement R1. The verification may occur concurrent
with or after the risk assessment performed under Requirement R1. [VRF: Medium;
Time-Horizon: Long-term Planning]
2.1. Each Transmission Owner shall select an unaffiliated verifying entity that is
either:

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CIP-014-3 — Physical Security
• A registered Planning Coordinator, Transmission Planner, or Reliability
Coordinator; or
• An entity that has transmission planning or analysis experience.
2.2. The unaffiliated third party verification shall verify the Transmission Owner’s risk
assessment performed under Requirement R1, which may include
recommendations for the addition or deletion of a Transmission station(s) or
Transmission substation(s). The Transmission Owner shall ensure the
verification is completed within 90 calendar days following the completion of the
Requirement R1 risk assessment.
2.3. If the unaffiliated verifying entity recommends that the Transmission Owner add
a Transmission station(s) or Transmission substation(s) to, or remove a
Transmission station(s) or Transmission substation(s) from, its identification
under Requirement R1, the Transmission Owner shall either, within 60 calendar
days of completion of the verification, for each recommended addition or
removal of a Transmission station or Transmission substation:
• Modify its identification under Requirement R1 consistent with the
recommendation; or
• Document the technical basis for not modifying the identification in
accordance with the recommendation.
2.4. Each Transmission Owner shall implement procedures, such as the use of nondisclosure agreements, for protecting sensitive or confidential information made
available to the unaffiliated third party verifier and to protect or exempt
sensitive or confidential information developed pursuant to this Reliability
Standard from public disclosure.
M2. Examples of acceptable evidence may include, but are not limited to, dated written or
electronic documentation that the Transmission Owner completed an unaffiliated
third party verification of the Requirement R1 risk assessment and satisfied all of the
applicable provisions of Requirement R2, including, if applicable, documenting the
technical basis for not modifying the Requirement R1 identification as specified under
Part 2.3. Additionally, examples of evidence may include, but are not limited to,
written or electronic documentation of procedures to protect information under Part
2.4.
R3.

For a primary control center(s) identified by the Transmission Owner according to
Requirement R1, Part 1.2 that a) operationally controls an identified Transmission
station or Transmission substation verified according to Requirement R2, and b) is not
under the operational control of the Transmission Owner: the Transmission Owner
shall, within seven calendar days following completion of Requirement R2, notify the
Transmission Operator that has operational control of the primary control center of

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CIP-014-3 — Physical Security
such identification and the date of completion of Requirement R2. [VRF: Lower; TimeHorizon: Long-term Planning]
3.1. If a Transmission station or Transmission substation previously identified under
Requirement R1 and verified according to Requirement R2 is removed from the
identification during a subsequent risk assessment performed according to
Requirement R1 or a verification according to Requirement R2, then the
Transmission Owner shall, within seven calendar days following the verification
or the subsequent risk assessment, notify the Transmission Operator that has
operational control of the primary control center of the removal.
M3. Examples of acceptable evidence may include, but are not limited to, dated written or
electronic notifications or communications that the Transmission Owner notified each
Transmission Operator, as applicable, according to Requirement R3.
R4. Each Transmission Owner that identified a Transmission station, Transmission
substation, or a primary control center in Requirement R1 and verified according to
Requirement R2, and each Transmission Operator notified by a Transmission Owner
according to Requirement R3, shall conduct an evaluation of the potential threats and
vulnerabilities of a physical attack to each of their respective Transmission station(s),
Transmission substation(s), and primary control center(s) identified in Requirement
R1 and verified according to Requirement R2. The evaluation shall consider the
following: [VRF: Medium; Time-Horizon: Operations Planning, Long-term Planning]
4.1. Unique characteristics of the identified and verified Transmission station(s),
Transmission substation(s), and primary control center(s);
4.2. Prior history of attack on similar facilities taking into account the frequency,
geographic proximity, and severity of past physical security related events; and
4.3. Intelligence or threat warnings received from sources such as law enforcement,
the Electric Reliability Organization (ERO), the Electricity Sector Information
Sharing and Analysis Center (ES-ISAC), U.S. federal and/or Canadian
governmental agencies, or their successors.
M4. Examples of evidence may include, but are not limited to, dated written or electronic
documentation that the Transmission Owner or Transmission Operator conducted an
evaluation of the potential threats and vulnerabilities of a physical attack to their
respective Transmission station(s), Transmission substation(s) and primary control
center(s) as specified in Requirement R4.
R5. Each Transmission Owner that identified a Transmission station, Transmission
substation, or primary control center in Requirement R1 and verified according to
Requirement R2, and each Transmission Operator notified by a Transmission Owner
according to Requirement R3, shall develop and implement a documented physical
security plan(s) that covers their respective Transmission station(s), Transmission
substation(s), and primary control center(s). The physical security plan(s) shall be

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CIP-014-3 — Physical Security
developed within 120 calendar days following the completion of Requirement R2 and
executed according to the timeline specified in the physical security plan(s). The
physical security plan(s) shall include the following attributes: [VRF: High; TimeHorizon: Long-term Planning]
5.1. Resiliency or security measures designed collectively to deter, detect, delay,
assess, communicate, and respond to potential physical threats and
vulnerabilities identified during the evaluation conducted in Requirement R4.
5.2. Law enforcement contact and coordination information.
5.3. A timeline for executing the physical security enhancements and modifications
specified in the physical security plan.
5.4. Provisions to evaluate evolving physical threats, and their corresponding security
measures, to the Transmission station(s), Transmission substation(s), or primary
control center(s).
M5. Examples of evidence may include, but are not limited to, dated written or electronic
documentation of its physical security plan(s) that covers their respective identified
and verified Transmission station(s), Transmission substation(s), and primary control
center(s) as specified in Requirement R5, and additional evidence demonstrating
execution of the physical security plan according to the timeline specified in the
physical security plan.
R6.

Each Transmission Owner that identified a Transmission station, Transmission
substation, or primary control center in Requirement R1 and verified according to
Requirement R2, and each Transmission Operator notified by a Transmission Owner
according to Requirement R3, shall have an unaffiliated third party review the
evaluation performed under Requirement R4 and the security plan(s) developed
under Requirement R5. The review may occur concurrently with or after completion
of the evaluation performed under Requirement R4 and the security plan
development under Requirement R5. [VRF: Medium; Time-Horizon: Long-term
Planning]
6.1. Each Transmission Owner and Transmission Operator shall select an unaffiliated
third party reviewer from the following:
•

An entity or organization with electric industry physical security experience
and whose review staff has at least one member who holds either a Certified
Protection Professional (CPP) or Physical Security Professional (PSP)
certification.

•

An entity or organization approved by the ERO.

•

A governmental agency with physical security expertise.

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CIP-014-3 — Physical Security
•

An entity or organization with demonstrated law enforcement, government,
or military physical security expertise.

6.2. The Transmission Owner or Transmission Operator, respectively, shall ensure
that the unaffiliated third party review is completed within 90 calendar days of
completing the security plan(s) developed in Requirement R5. The unaffiliated
third party review may, but is not required to, include recommended changes to
the evaluation performed under Requirement R4 or the security plan(s)
developed under Requirement R5.
6.3. If the unaffiliated third party reviewer recommends changes to the evaluation
performed under Requirement R4 or security plan(s) developed under
Requirement R5, the Transmission Owner or Transmission Operator shall, within
60 calendar days of the completion of the unaffiliated third party review, for
each recommendation:
• Modify its evaluation or security plan(s) consistent with the recommendation;
or
• Document the reason(s) for not modifying the evaluation or security plan(s)
consistent with the recommendation.
6.4. Each Transmission Owner and Transmission Operator shall implement
procedures, such as the use of non-disclosure agreements, for protecting
sensitive or confidential information made available to the unaffiliated third
party reviewer and to protect or exempt sensitive or confidential information
developed pursuant to this Reliability Standard from public disclosure.
M6. Examples of evidence may include, but are not limited to, written or electronic
documentation that the Transmission Owner or Transmission Operator had an
unaffiliated third party review the evaluation performed under Requirement R4 and
the security plan(s) developed under Requirement R5 as specified in Requirement R6
including, if applicable, documenting the reasons for not modifying the evaluation or
security plan(s) in accordance with a recommendation under Part 6.3. Additionally,
examples of evidence may include, but are not limited to, written or electronic
documentation of procedures to protect information under Part 6.4.

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CIP-014-3 — Physical Security
C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority
As defined in the NERC Rules of Procedure, “Compliance Enforcement Authority” (CEA) means NERC or the Regional
Entity in their respective roles of monitoring and enforcing compliance with the NERC Reliability Standards.
1.2. Evidence Retention
The following evidence retention periods identify the period of time an entity is required to retain specific evidence to
demonstrate compliance. For instances where the evidence retention period specified below is shorter than the time
since the last audit, the CEA may ask an entity to provide other evidence during an on-site visit to show that it was
compliant for the full time period since the last audit.
The Transmission Owner and Transmission Operator shall keep data or evidence to show compliance, as identified
below, unless directed by its Compliance Enforcement Authority (CEA) to retain specific evidence for a longer period
of time as part of an investigation.
The responsible entities shall retain documentation as evidence for three years.
If a Responsible Entity is found non-compliant, it shall keep information related to the non-compliance until
mitigation is complete and approved, or for the time specified above, whichever is longer.
The CEA shall keep the last audit records and all requested and submitted subsequent audit records, subject to the
confidentiality provisions of Section 1500 of the Rules of Procedure and the provisions of Section 1.4 below.
1.3. Compliance Monitoring and Assessment Processes:
Compliance Audits
Self-Certifications
Spot Checking
Compliance Violation Investigations
Self-Reporting
Complaints Text

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CIP-014-3 — Physical Security

2. Table of Compliance Elements

R#

R1

Time
Horizon
Long-term
Planning

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

High

The Transmission
Owner performed an
initial risk
assessment but did
so after the date
specified in the
implementation plan
for performing the
initial risk
assessment but less
than or equal to two
calendar months
after that date;
OR
The Transmission
Owner that has
identified in its
previous risk
assessment one or
more Transmission
stations or
Transmission
substations that if
rendered inoperable

Moderate VSL

High VSL

Severe VSL

The Transmission
Owner performed an
initial risk assessment
but did so more than
two calendar months
after the date
specified in the
implementation plan
for performing the
initial risk assessment
but less than or equal
to four calendar
months after that
date;

The Transmission
Owner performed an
initial risk assessment
but did so more than
four calendar months
after the date
specified in the
implementation plan
for performing the
initial risk assessment
but less than or equal
to six calendar months
after that date;

The Transmission
Owner performed an
initial risk
assessment but did
so more than six
calendar months
after the date
specified in the
implementation plan
for performing the
initial risk
assessment;

OR

OR
The Transmission
Owner that has
identified in its
previous risk
assessment one or
more Transmission
stations or
Transmission
substations that if
rendered inoperable

The Transmission
Owner failed to
perform an initial
risk assessment;

The Transmission
Owner that has
identified in its
previous risk
assessment one or
more Transmission
stations or
Transmission
substations that if

OR

OR
The Transmission
Owner that has
identified in its
previous risk
assessment one or
more Transmission
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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection
performed a
subsequent risk
assessment but did
so after 30 calendar
months but less than
or equal to 32
calendar months;
OR
The Transmission
Owner that has not
identified in its
previous risk
assessment any
Transmission
stations or
Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an

Moderate VSL

High VSL

rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection
performed a
subsequent risk
assessment but did so
after 32 calendar
months but less than
or equal to 34
calendar months;

or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection
performed a
subsequent risk
assessment but did so
after 34 calendar
months but less than
or equal to 36
calendar months;

OR

The Transmission
Owner that has not
identified in its
previous risk
assessment any
Transmission stations
or Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection

The Transmission
Owner that has not
identified in its
previous risk
assessment any
Transmission stations
or Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an

OR

Severe VSL
stations or
Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection
performed a
subsequent risk
assessment but did
so after more than
36 calendar months;
OR
The Transmission
Owner that has
identified in its
previous risk
assessment one or
more Transmission
stations or
Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL
Interconnection
performed a
subsequent risk
assessment but did
so after 60 calendar
months but less than
or equal to 62
calendar months.

Moderate VSL
Interconnection
performed a
subsequent risk
assessment but did so
after 62 calendar
months but less than
or equal to 64
calendar months.

High VSL
performed a
subsequent risk
assessment but did so
after 64 calendar
months but less than
or equal to 66
calendar months;
OR
The Transmission
Owner performed a
risk assessment but
failed to include Part
1.2.

Severe VSL
separation, or
Cascading within an
Interconnection
failed to perform a
risk assessment;
OR
The Transmission
Owner that has not
identified in its
previous risk
assessment any
Transmission
stations or
Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection
performed a
subsequent risk
assessment but did
so after more than
66 calendar months;
OR
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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

Moderate VSL

High VSL

Severe VSL
The Transmission
Owner that has not
identified in its
previous risk
assessment any
Transmission station
and Transmission
substations that if
rendered inoperable
or damaged could
result in instability,
uncontrolled
separation, or
Cascading within an
Interconnection
failed to perform a
subsequent risk
assessment.

R2

Long-term
Planning

Medium

The Transmission
Owner had an
unaffiliated third
party verify the risk
assessment
performed under
Requirement R1 but
did so in more than
90 calendar days but
less than or equal to
100 calendar days

The Transmission
Owner had an
unaffiliated third
party verify the risk
assessment
performed under
Requirement R1 but
did so more than 100
calendar days but
less than or equal to
110 calendar days

The Transmission
Owner had an
unaffiliated third party
verify the risk
assessment performed
under Requirement R1
but did so more than
110 calendar days but
less than or equal to
120 calendar days

The Transmission
Owner had an
unaffiliated third
party verify the risk
assessment
performed under
Requirement R1 but
did so more than
120 calendar days
following
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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

Moderate VSL

High VSL

Severe VSL

following completion
of Requirement R1;

following completion
of Requirement R1;

following completion
of Requirement R1;

completion of
Requirement R1;

OR

Or

OR

OR

The Transmission
Owner had an
unaffiliated third
party verify the risk
assessment
performed under
Requirement R1 and
modified or
documented the
technical basis for
not modifying its
identification under
Requirement R1 as
required by Part 2.3
but did so more than
60 calendar days and
less than or equal to
70 calendar days
from completion of
the third party
verification.

The Transmission
Owner had an
unaffiliated third
party verify the risk
assessment
performed under
Requirement R1 and
modified or
documented the
technical basis for
not modifying its
identification under
Requirement R1 as
required by Part 2.3
but did so more than
70 calendar days and
less than or equal to
80 calendar days
from completion of
the third party
verification.

The Transmission
Owner had an
unaffiliated third party
verify the risk
assessment performed
under Requirement R1
and modified or
documented the
technical basis for not
modifying its
identification under
Requirement R1 as
required by Part 2.3
but did so more than
80 calendar days from
completion of the
third party
verification;

The Transmission
Owner failed to have
an unaffiliated third
party verify the risk
assessment
performed under
Requirement R1;

OR
The Transmission
Owner had an
unaffiliated third party
verify the risk
assessment performed
under Requirement R1

OR
The Transmission
Owner had an
unaffiliated third
party verify the risk
assessment
performed under
Requirement R1 but
failed to implement
procedures for
protecting
information per Part
2.4.

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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

Moderate VSL

High VSL

Severe VSL

but failed to modify or
document the
technical basis for not
modifying its
identification under
R1 as required by Part
2.3.
R3

Long-term
Planning

Lower

The Transmission
Owner notified the
Transmission
Operator that
operates the primary
control center as
specified in
Requirement R3 but
did so more than
seven calendar days
and less than or equal
to nine calendar days
following the
completion of
Requirement R2;

The Transmission
Owner notified the
Transmission
Operator that
operates the primary
control center as
specified in
Requirement R3 but
did so more than nine
calendar days and
less than or equal to
11 calendar days
following the
completion of
Requirement R2;

OR

OR

The Transmission
Owner notified the
Transmission
Operator that
operates the primary

The Transmission
Owner notified the
Transmission
Operator that
operates the primary

The Transmission
Owner notified the
Transmission Operator
that operates the
primary control center
as specified in
Requirement R3 but
did so more than 11
calendar days and less
than or equal to 13
calendar days
following the
completion of
Requirement R2;

The Transmission
Owner notified the
Transmission
Operator that
operates the primary
control center as
specified in
Requirement R3 but
did so more than 13
calendar days
following the
completion of
Requirement R2;

OR

The Transmission
Owner failed to
notify the
Transmission
Operator that it
operates a control

The Transmission
Owner notified the
Transmission Operator
that operates the
primary control center
of the removal from

OR

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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL
control center of the
removal from the
identification in
Requirement R1 but
did so more than
seven calendar days
and less than or equal
to nine calendar days
following the
verification or the
subsequent risk
assessment.

Moderate VSL
control center of the
removal from the
identification in
Requirement R1 but
did so more than nine
calendar days and
less than or equal to
11 calendar days
following the
verification or the
subsequent risk
assessment.

High VSL
the identification in
Requirement R1 but
did so more than 11
calendar days and less
than or equal to 13
calendar days
following the
verification or the
subsequent risk
assessment.

Severe VSL
center identified in
Requirement R1;
OR
The Transmission
Owner notified the
Transmission
Operator that
operates the primary
control center of the
removal from the
identification in
Requirement R1 but
did so more than 13
calendar days
following the
verification or the
subsequent risk
assessment.
OR
The Transmission
Owner failed to
notify the
Transmission
Operator that
operates the primary
control center of the
removal from the
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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

Moderate VSL

High VSL

Severe VSL
identification in
Requirement R1.

R4

Operations
Planning,
Long-term
Planning

Medium

N/A

The Responsible
Entity conducted an
evaluation of the
potential physical
threats and
vulnerabilities to
each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified
in Requirement R1
but failed to
consider one of
Parts 4.1 through 4.3
in the evaluation.

The Responsible
Entity conducted an
evaluation of the
potential physical
threats and
vulnerabilities to
each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 but
failed to consider two
of Parts 4.1 through
4.3 in the evaluation.

The Responsible
Entity failed to
conduct an
evaluation of the
potential physical
threats and
vulnerabilities to
each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified
in Requirement R1;
OR
The Responsible
Entity conducted an
evaluation of the
potential physical
threats and
vulnerabilities to
each of its
Transmission
station(s),
Transmission
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CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

Moderate VSL

High VSL

Severe VSL
substation(s), and
primary control
center(s) identified
in Requirement R1
but failed to
consider Parts 4.1
through 4.3.

R5

Long-term
Planning

High

The Responsible
Entity developed and
implemented a
documented physical
security plan(s) that
covers each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 but
did so more than 120
calendar days but
less than or equal to
130 calendar days
after completing
Requirement R2;

The Responsible
Entity developed and
implemented a
documented physical
security plan(s) that
covers each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 but
did so more than 130
calendar days but
less than or equal to
140 calendar days
after completing
Requirement R2;

The Responsible Entity
developed and
implemented a
documented physical
security plan(s) that
covers each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 but
did so more than 140
calendar days but less
than or equal to 150
calendar days after
completing
Requirement R2;

The Responsible
Entity developed and
implemented a
documented
physical security
plan(s) that covers
each of its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified
in Requirement R1
but did so more than
150 calendar days
after completing the
verification in
Requirement R2;

OR

OR

OR

OR

Page 17 of 36

CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL
The Responsible
Entity developed and
implemented a
documented physical
security plan(s) that
covers its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 and
verified according to
Requirement R2 but
failed to include one
of Parts 5.1 through
5.4 in the plan.

Moderate VSL
The Responsible
Entity developed and
implemented a
documented physical
security plan(s) that
covers its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 and
verified according to
Requirement R2 but
failed to include two
of Parts 5.1 through
5.4 in the plan.

High VSL
The Responsible Entity
developed and
implemented a
documented physical
security plan(s) that
covers its
Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified in
Requirement R1 and
verified according to
Requirement R2 but
failed to include three
of Parts 5.1 through
5.4 in the plan.

Severe VSL
The Responsible
Entity failed to
develop and
implement a
documented
physical security
plan(s) that covers
its Transmission
station(s),
Transmission
substation(s), and
primary control
center(s) identified
in Requirement R1
and verified
according to
Requirement R2.
OR
The Responsible
Entity developed and
implemented a
documented
physical security
plan(s) that covers
its Transmission
station(s),
Transmission
substation(s), and
primary control
Page 18 of 36

CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL

Moderate VSL

High VSL

Severe VSL
center(s) identified
in Requirement R1
and verified
according to
Requirement 2 but
failed to include
Parts 5.1 through 5.4
in the plan.

R6

Long-term
Planning

Medium

The Responsible
Entity had an
unaffiliated third
party review the
evaluation performed
under Requirement
R4 and the security
plan(s) developed
under Requirement
R5 but did so in more
than 90 calendar days
but less than or equal
to 100 calendar days;
OR

The Responsible
Entity had an
unaffiliated third
party review the
evaluation performed
under Requirement
R4 and the security
plan(s) developed
under Requirement
R5 but did so in more
than 100 calendar
days but less than or
equal to 110 calendar
days;

The Responsible
Entity had an
unaffiliated third
party review the
evaluation performed
under Requirement

The Responsible
Entity had an
unaffiliated third
party review the
evaluation performed

OR

The Responsible Entity
had an unaffiliated
third party review the
evaluation performed
under Requirement R4
and the security
plan(s) developed
under Requirement R5
but did so more than
110 calendar days but
less than or equal to
120 calendar days;

The Responsible
Entity failed to have
an unaffiliated third
party review the
evaluation
performed under
Requirement R4 and
the security plan(s)
developed under
Requirement R5 in
more than 120
calendar days;

OR

OR

The Responsible Entity
had an unaffiliated
third party review the
evaluation performed
under Requirement R4
and the security
plan(s) developed

The Responsible
Entity failed to have
an unaffiliated third
party review the
evaluation
performed under
Requirement R4 and
Page 19 of 36

CIP-014-3 — Physical Security
R#

Time
Horizon

VRF

Violation Severity Levels (CIP-014-3)
Lower VSL
R4 and the security
plan(s) developed
under Requirement
R5 and modified or
documented the
reason for not
modifying the
security plan(s) as
specified in Part 6.3
but did so more than
60 calendar days and
less than or equal to
70 calendar days
following completion
of the third party
review.

Moderate VSL
under Requirement
R4 and the security
plan(s) developed
under Requirement
R5 and modified or
documented the
reason for not
modifying the
security plan(s) as
specified in Part 6.3
but did so more than
70 calendar days and
less than or equal to
80 calendar days
following completion
of the third party
review.

High VSL
under Requirement R5
and modified or
documented the
reason for not
modifying the security
plan(s) as specified in
Part 6.3 but did so
more than 80 calendar
days following
completion of the
third party review;
OR
The Responsible Entity
had an unaffiliated
third party review the
evaluation performed
under Requirement R4
and the security
plan(s) developed
under Requirement R5
but did not document
the reason for not
modifying the security
plan(s) as specified in
Part 6.3.

Severe VSL
the security plan(s)
developed under
Requirement R5;
OR
The Responsible
Entity had an
unaffiliated third
party review the
evaluation
performed under
Requirement R4 and
the security plan(s)
developed under
Requirement R5 but
failed to implement
procedures for
protecting
information per Part
6.4.

Page 20 of 36

Guidelines and Technical Basis
D. Regional Variances
None.
E. Interpretations
None.
F. Associated Documents
None.

Version History
Version

Date

Action

Change Tracking

1

October 1,
2015

Effective Date

New

2

April 16, 2015

Revised to meet FERC Order 802
directive to remove “widespread”.

Revision

2

May 7, 2015

Adopted by the NERC Board of Trustees

2

July 14, 2015

FERC Letter Order in Docket No.
RD15-4-000 approving CIP-014-2

3

January 19,
2022

Revised to remove Compliance Section
1.4

3

June 16, 2022

FERC Letter Order in Docket No.RD22-3- Revision
000 approving Modifications to CIP014-3

3

June 16,2022

Effective Date

Revision

Revision

Guidelines and Technical Basis
Section 4 Applicability

The purpose of Reliability Standard CIP-014 is to protect Transmission stations and
Transmission substations, and their associated primary control centers that if rendered
inoperable or damaged as a result of a physical attack could result in instability, uncontrolled
separation, or Cascading within an Interconnection. To properly include those entities that own
or operate such Facilities, the Reliability Standard CIP-014 first applies to Transmission Owners
that own Transmission Facilities that meet the specific criteria in Applicability Section 4.1.1.1
through 4.1.1.4. The Facilities described in Applicability Section 4.1.1.1 through 4.1.1.4 mirror

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Guidelines and Technical Basis
those Transmission Facilities that meet the bright line criteria for “Medium Impact”
Transmission Facilities under Attachment 1 of Reliability Standard CIP-002-5.1. Each
Transmission Owner that owns Transmission Facilities that meet the criteria in Section 4.1.1.1
through 4.1.1.4 is required to perform a risk assessment as specified in Requirement R1 to
identify its Transmission stations and Transmission substations, and their associated primary
control centers, that if rendered inoperable or damaged as a result of a physical attack could
result in instability, uncontrolled separation, or Cascading within an Interconnection. The
Standard Drafting Team (SDT) expects this population will be small and that many Transmission
Owners that meet the applicability of this standard will not actually identify any such Facilities.
Only those Transmission Owners with Transmission stations or Transmission substations
identified in the risk assessment (and verified under Requirement R2) have performance
obligations under Requirements R3 through R6.
This standard also applies to Transmission Operators. A Transmission Operator’s obligations
under the standard, however, are only triggered if the Transmission Operator is notified by an
applicable Transmission Owner under Requirement R3 that the Transmission Operator operates
a primary control center that operationally controls a Transmission station(s) or Transmission
substation(s) identified in the Requirement R1 risk assessment. A primary control center
operationally controls a Transmission station or Transmission substation when the control
center’s electronic actions can cause direct physical action at the identified Transmission
station or Transmission substation, such as opening a breaker, as opposed to a control center
that only has information from the Transmission station or Transmission substation and must
coordinate direct action through another entity. Only Transmission Operators who are notified
that they have primary control centers under this standard have performance obligations under
Requirements R4 through R6. In other words, primary control center for purposes of this
Standard is the control center that the Transmission Owner or Transmission Operator,
respectively, uses as its primary, permanently-manned site to physically operate a Transmission
station or Transmission substation that is identified in Requirement R1 and verified in
Requirement R2. Control centers that provide back-up capability are not applicable, as they
are a form of resiliency and intentionally redundant.
The SDT considered several options for bright line criteria that could be used to determine
applicability and provide an initial threshold that defines the set of Transmission stations and
Transmission substations that would meet the directives of the FERC order on physical security
(i.e., those that could cause instability, uncontrolled separation, or Cascading within an
Interconnection). The SDT determined that using the criteria for Medium Impact Transmission
Facilities in Attachment 1 of CIP-002-5.1 would provide a conservative threshold for defining
which Transmission stations and Transmission substations must be included in the risk
assessment in Requirement R1 of CIP-014. Additionally, the SDT concluded that using the CIP002-5.1 Medium Impact criteria was appropriate because it has been approved by
stakeholders, NERC, and FERC, and its use provides a technically sound basis to determine
which Transmission Owners should conduct the risk assessment. As described in CIP-002-5.1,
the failure of a Transmission station or Transmission substation that meets the Medium Impact
criteria could have the capability to result in exceeding one or more Interconnection Reliability
Operating Limits (IROLs). The SDT understands that using this bright line criteria to determine
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Guidelines and Technical Basis
applicability may require some Transmission Owners to perform risk assessments under
Requirement R1 that will result in a finding that none of their Transmission stations or
Transmission substations would pose a risk of instability, uncontrolled separation, or Cascading
within an Interconnection. However, the SDT determined that higher bright lines could not be
technically justified to ensure inclusion of all Transmission stations and Transmission
substations, and their associated primary control centers that, if rendered inoperable or
damaged as a result of a physical attack could result in instability, uncontrolled separation, or
Cascading within an Interconnection. Further guidance and technical basis for the bright line
criteria for Medium Impact Facilities can be found in the Guidelines and Technical Basis section
of CIP-002-5.1.
Additionally, the SDT determined that it was not necessary to include Generator Operators and
Generator Owners in the Reliability Standard. First, Transmission stations or Transmission
substations interconnecting generation facilities are considered when determining applicability.
Transmission Owners will consider those Transmission stations and Transmission substations
that include a Transmission station on the high side of the Generator Step-up transformer
(GSU) using Applicability Section 4.1.1.1 and 4.1.1.2. As an example, a Transmission station or
Transmission substation identified as a Transmission Owner facility that interconnects
generation will be subject to the Requirement R1 risk assessment if it operates at 500kV or
greater or if it is connected at 200 kV – 499kV to three or more other Transmission stations or
Transmission substations and has an "aggregate weighted value" exceeding 3000 according to
the table in Applicability Section 4.1.1.2. Second, the Transmission analysis or analyses
conducted under Requirement R1 should take into account the impact of the loss of generation
connected to applicable Transmission stations or Transmission substations. Additionally, the
FERC order does not explicitly mention generation assets and is reasonably understood to focus
on the most critical Transmission Facilities. The diagram below shows an example of a station.

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Guidelines and Technical Basis

Also, the SDT uses the phrase “Transmission stations or Transmission substations” to recognize
the existence of both stations and substations. Many entities in industry consider a substation
to be a location with physical borders (i.e. fence, wall, etc.) that contains at least an
autotransformer. Locations also exist that do not contain autotransformers, and many entities
in industry refer to those locations as stations (switching stations or switchyards). Therefore,
the SDT chose to use both “station” and “substation” to refer to the locations where groups of
Transmission Facilities exist.
On the issue of joint ownership, the SDT recognizes that this issue is not unique to CIP-014, and
expects that the applicable Transmission Owners and Transmission Operators will develop
memorandums of understanding, agreements, Coordinated Functional Registrations, or
procedures, etc., to designate responsibilities under CIP-014 when joint ownership is at issue,
which is similar to what many entities have completed for other Reliability Standards.
The language contained in the applicability section regarding the collector bus is directly copied
from CIP-002-5.1, Attachment 1, and has no additional meaning within the CIP-014 standard.
Requirement R1

The initial risk assessment required under Requirement R1 must be completed on or before the
effective date of the standard. Subsequent risk assessments are to be performed at least once
every 30 or 60 months depending on the results of the previous risk assessment per
Requirement R1, Part 1.1. In performing the risk assessment under Requirement R1, the
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Guidelines and Technical Basis
Transmission Owner should first identify their population of Transmission stations and
Transmission substations that meet the criteria contained in Applicability Section 4.1.1.
Requirement R1 then requires the Transmission Owner to perform a risk assessment, consisting
of a transmission analysis, to determine which of those Transmission stations and Transmission
Substations if rendered inoperable or damaged could result in instability, uncontrolled
separation, or Cascading within an Interconnection. The requirement is not to require
identification of, and thus, not intended to bring within the scope of the standard a
Transmission station or Transmission substation unless the applicable Transmission Owner
determines through technical studies and analyses based on objective analysis, technical
expertise, operating experience and experienced judgment that the loss of such facility would
have a critical impact on the operation of the Interconnection in the event the asset is rendered
inoperable or damaged. In the November 20, 2014 Order, FERC reiterated that “only an
instability that has a “critical impact on the operation of the interconnection” warrants finding
that the facility causing the instability is critical under Requirement R1.” The Transmission
Owner may determine the criteria for critical impact by considering, among other criteria, any
of the following:
•

Criteria or methodology used by Transmission Planners or Planning Coordinators in TPL001-4, Requirement R6

•

NERC EOP-004-2 reporting criteria

•

Area or magnitude of potential impact

The standard does not mandate the specific analytical method for performing the risk
assessment. The Transmission Owner has the discretion to choose the specific method that
best suites its needs. As an example, an entity may perform a Power Flow analysis and stability
analysis at a variety of load levels.
Performing Risk Assessments
The Transmission Owner has the discretion to select a transmission analysis method that fits its
facts and system circumstances. To mandate a specific approach is not technically desirable
and may lead to results that fail to adequately consider regional, topological, and system
circumstances. The following guidance is only an example on how a Transmission Owner may
perform a power flow and/or stability analysis to identify those Transmission stations and
Transmission substations that if rendered inoperable or damaged as a result of a physical attack
could result in instability, uncontrolled separation, or Cascading within an Interconnection. An
entity could remove all lines, without regard to the voltage level, to a single Transmission
station or Transmission substation and review the simulation results to assess system behavior
to determine if Cascading of Transmission Facilities, uncontrolled separation, or voltage or
frequency instability is likely to occur over a significant area of the Interconnection. Using
engineering judgment, the Transmission Owner (possibly in consultation with regional planning
or operation committees and/or ISO/RTO committee input) should develop criteria (e.g.
imposing a fault near the removed Transmission station or Transmission substation) to identify
a contingency or parameters that result in potential instability, uncontrolled separation, or
Cascading within an Interconnection. Regional consultation on these matters is likely to be

Page 25 of 36

Guidelines and Technical Basis
helpful and informative, given that the inputs for the risk assessment and the attributes of what
constitutes instability, uncontrolled separation, or Cascading within an Interconnection will
likely vary from region-to-region or from ISO-to-ISO based on topology, system characteristics,
and system configurations. Criteria could also include post-contingency facilities loadings above
a certain emergency rating or failure of a power flow case to converge. Available special
protection systems (SPS), if any, could be applied to determine if the system experiences any
additional instability which may result in uncontrolled separation. Example criteria may
include:
(a) Thermal overloads beyond facility emergency ratings;
(b) Voltage deviation exceeding ± 10%; or
(c) Cascading outage/voltage collapse; or
(d) Frequency below under-frequency load shed points

Periodicity
A Transmission Owner who identifies one or more Transmission stations or Transmission
substations (as verified under Requirement R2) that if rendered inoperable or damaged could
result in instability, uncontrolled separation, or Cascading within an Interconnection is required
to conduct a risk assessment at least once every 30 months. This period ensures that the risk
assessment remains current with projected conditions and configurations in the planned
system. This risk assessment, as the initial assessment, must consider applicable planned
Transmission stations and Transmission substations to be in service within 24 months. The 30
month timeframe aligns with the 24 month planned to be in service date because the
Transmission Owner is provided the flexibility, depending on its planning cycle and the
frequency in which it may plan to construct a new Transmission station or Transmission
substation to more closely align these dates. The requirement is to conduct the risk assessment
at least once every 30 months, so for a Transmission Owner that believes it is better to conduct
a risk assessment once every 24 months, because of its planning cycle, it has the flexibility to do
so.
Transmission Owners that have not identified any Transmission stations or Transmission
substations (as verified under Requirement R2) that if rendered inoperable or damaged could
result in instability, uncontrolled separation, or Cascading within an Interconnection are
unlikely to see changes to their risk assessment in the Near-Term Planning Horizon.
Consequently, a 60 month periodicity for completing a subsequent risk assessment is specified.
Identification of Primary Control Centers
After completing the risk assessment specified in Requirement R1, it is important to additionally
identify the primary control center that operationally controls each Transmission station or
Transmission substation that if rendered inoperable or damaged could result in instability,
uncontrolled separation, or Cascading within an Interconnection. A primary control center

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Guidelines and Technical Basis
“operationally controls” a Transmission station or Transmission substation when the control
center’s electronic actions can cause direct physical actions at the identified Transmission
station and Transmission substation, such as opening a breaker.
Requirement R2

This requirement specifies verification of the risk assessment performed under Requirement R1
by an entity other than the owner or operator of the Requirement R1 risk assessment.
A verification of the risk assessment by an unaffiliated third party, as specified in Requirement
R2, could consist of:
1. Certifying that the Requirement R1 risk assessment considers the Transmission stations
and Transmission substations identified in Applicability Section 4.1.1.
2. Review of the model used to conduct the risk assessment to ensure it contains sufficient
system topology to identify Transmission stations and Transmission substations that if
rendered inoperable or damaged could cause instability, uncontrolled separation, or
Cascading within an Interconnection.
3. Review of the Requirement R1 risk assessment methodology.
This requirement provides the flexibility for a Transmission Owner to select from unaffiliated
registered and non-registered entities with transmission planning or analysis experience to
perform the verification of the Requirement R1 risk assessment. The term unaffiliated means
that the selected verifying entity cannot be a corporate affiliate (i.e., the verifying or third party
reviewer cannot be an entity that corporately controls, is controlled by or is under common
control with, the Transmission Owner). The verifying entity also cannot be a division of the
Transmission Owner that operates as a functional unit.
The prohibition on registered entities using a corporate affiliate to conduct the verification,
however, does not prohibit a governmental entity (e.g., a city, a municipality, a U.S. federal
power marketing agency, or any other political subdivision of U.S. or Canadian federal, state, or
provincial governments) from selecting as the verifying entity another governmental entity
within the same political subdivision. For instance, a U.S. federal power marketing agency may
select as its verifier another U.S. federal agency to conduct its verification so long as the
selected entity has transmission planning or analysis experience. Similarly, a Transmission
Owner owned by a Canadian province can use a separate agency of that province to perform
the verification. The verifying entity, however, must still be a third party and cannot be a
division of the registered entity that operates as a functional unit.
Requirement R2 also provides that the “verification may occur concurrent with or after the risk
assessment performed under Requirement R1.” This provision is designed to provide the
Transmission Owner the flexibility to work with the verifying entity throughout (i.e., concurrent
with) the risk assessment, which for some Transmission Owners may be more efficient and
effective. In other words, a Transmission Owner could collaborate with their unaffiliated
verifying entity to perform the risk assessment under Requirement R1 such that both
Requirement R1 and Requirement R2 are satisfied concurrently. The intent of Requirement R2
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Guidelines and Technical Basis
is to have an entity other than the owner or operator of the facility to be involved in the risk
assessment process and have an opportunity to provide input. Accordingly, Requirement R2 is
designed to allow entities the discretion to have a two-step process, where the Transmission
Owner performs the risk assessment and subsequently has a third party review that
assessment, or a one-step process, where the entity collaborates with a third party to perform
the risk assessment.
Characteristics to consider in selecting a third party reviewer could include:
•

Registered Entity with applicable planning and reliability functions.

•

Experience in power system studies and planning.

•

The entity’s understanding of the MOD standards, TPL standards, and facility ratings as
they pertain to planning studies.

•

The entity’s familiarity with the Interconnection within which the Transmission Owner is
located.

With respect to the requirement that Transmission owners develop and implement procedures
for protecting confidential and sensitive information, the Transmission Owner could have a
method for identifying documents that require confidential treatment. One mechanism for
protecting confidential or sensitive information is to prohibit removal of sensitive or
confidential information from the Transmission Owner’s site. Transmission Owners could
include such a prohibition in a non-disclosure agreement with the verifying entity.
A Technical feasibility study is not required in the Requirement R2 documentation of the
technical basis for not modifying the identification in accordance with the recommendation.
On the issue of the difference between a verifier in Requirement R2 and a reviewer in
Requirement R6, the SDT indicates that the verifier will confirm that the risk assessment was
completed in accordance with Requirement R1, including the number of Transmission stations
and substations identified, while the reviewer in Requirement R6 is providing expertise on the
manner in which the evaluation of threats was conducted in accordance with Requirement R4,
and the physical security plan in accordance with Requirement R5. In the latter situation there
is no verification of a technical analysis, rather an application of experience and expertise to
provide guidance or recommendations, if needed.
Parts 2.4 and 6.4 require the entities to have procedures to protect the confidentiality of
sensitive or confidential information. Those procedures may include the following elements:
1.

Control and retention of information on site for third party verifiers/reviewers.

2.

Only “need to know” employees, etc., get the information.

3.

Marking documents as confidential

4.

Securely storing and destroying information when no longer needed.

5.

Not releasing information outside the entity without, for example, General
Counsel sign-off.

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Guidelines and Technical Basis
Requirement R3

Some Transmission Operators will have obligations under this standard for certain primary
control centers. Those obligations, however, are contingent upon a Transmission Owner first
completing the risk assessment specified by Requirement R1 and the verification specified by
Requirement R2. Requirement R3 is intended to ensure that a Transmission Operator that has
operational control of a primary control center identified in Requirement R1 receive notice so
that the Transmission Operator may fulfill the rest of the obligations required in Requirements
R4 through R6. Since the timing obligations in Requirements R4 through R6 are based upon
completion of Requirement R2, the Transmission Owner must also include within the notice the
date of completion of Requirement R2. Similarly, the Transmission Owner must notify the
Transmission Operator of any removals from identification that result from a subsequent risk
assessment under Requirement R1 or as a result of the verification process under Requirement
R2.
Requirement R4

This requirement requires owners and operators of facilities identified by the Requirement R1
risk assessment and that are verified under Requirement R2 to conduct an assessment of
potential threats and vulnerabilities to those Transmission stations, Transmission substations,
and primary control centers using a tailored evaluation process. Threats and vulnerabilities may
vary from facility to facility based on any number of factors that include, but are not limited to,
location, size, function, existing physical security protections, and attractiveness as a target.
In order to effectively conduct a threat and vulnerability assessment, the asset owner may be
the best source to determine specific site vulnerabilities, but current and evolving threats may
best be determined by others in the intelligence or law enforcement communities. A number of
resources have been identified in the standard, but many others exist and asset owners are not
limited to where they may turn for assistance. Additional resources may include state or local
fusion centers, U.S. Department of Homeland Security, Federal Bureau of Investigations (FBI),
Public Safety Canada, Royal Canadian Mounted Police, and InfraGard chapters coordinated by
the FBI.
The Responsible Entity is required to take a number of factors into account in Parts 4.1 to 4.3 in
order to make a risk-based evaluation under Requirement R4.
To assist in determining the current threat for a facility, the prior history of attacks on similarly
protected facilities should be considered when assessing probability and likelihood of
occurrence at the facility in question.
Resources that may be useful in conducting threat and vulnerability assessments include:
•

NERC Security Guideline for the Electricity Sector: Physical Security.

•

NERC Security Guideline: Physical Security Response.

•

ASIS International General Risk Assessment Guidelines.

•

ASIS International Facilities Physical Security Measure Guideline.
Page 29 of 36

Guidelines and Technical Basis
•

ASIS International Security Management Standard: Physical Asset Protection.

•

Whole Building Design Guide - Threat/Vulnerability Assessments.

Requirement R5

This requirement specifies development and implementation of a security plan(s) designed to
protect against attacks to the facilities identified in Requirement R1 based on the assessment
performed under Requirement R4.
Requirement R5 specifies the following attributes for the physical security plan:
•

Resiliency or security measures designed collectively to deter, detect, delay, assess,
communicate, and respond to potential physical threats and vulnerabilities identified
during the evaluation conducted in Requirement R4.
Resiliency may include, among other things:
a.

System topology changes,

b.

Spare equipment,

c.

Construction of a new Transmission station or Transmission substation.

While most security measures will work together to collectively harden the entire site,
some may be allocated to protect specific critical components. For example, if
protection from gunfire is considered necessary, the entity may only install ballistic
protection for critical components, not the entire site.
•

Law enforcement contact and coordination information.
Examples of such information may be posting 9-1-1 for emergency calls and providing
substation safety and familiarization training for local and federal law enforcement, fire
department, and Emergency Medical Services.

•

A timeline for executing the physical security enhancements and modifications specified
in the physical security plan.
Entities have the flexibility to prioritize the implementation of the various resiliency or
security enhancements and modifications in their security plan according to risk,
resources, or other factors. The requirement to include a timeline in the physical
security plan for executing the actual physical security enhancements and modifications
does not also require that the enhancements and modifications be completed within
120 days. The actual timeline may extend beyond the 120 days, depending on the
amount of work to be completed.

•

Provisions to evaluate evolving physical threats, and their corresponding security
measures, to the Transmission station(s), Transmission substation(s), or primary control
center(s).
A registered entity's physical security plan should include processes and responsibilities
for obtaining and handling alerts, intelligence, and threat warnings from various
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sources. Some of these sources could include the ERO, ES-ISAC, and US and/or Canadian
federal agencies. This information should be used to reevaluate or consider changes in
the security plan and corresponding security measures of the security plan found in R5.
Incremental changes made to the physical security plan prior to the next required third
party review do not require additional third party reviews.
Requirement R6

This requirement specifies review by an entity other than the Transmission Owner or
Transmission Operator with appropriate expertise for the evaluation performed according to
Requirement R4 and the security plan(s) developed according to Requirement R5. As with
Requirement R2, the term unaffiliated means that the selected third party reviewer cannot be a
corporate affiliate (i.e., the third party reviewer cannot be an entity that corporately controls, is
controlled by or is under common control with, the Transmission Operator). A third party
reviewer also cannot be a division of the Transmission Operator that operates as a functional
unit.
As noted in the guidance for Requirement R2, the prohibition on registered entities using a
corporate affiliate to conduct the review, however, does not prohibit a governmental entity
from selecting as the third party reviewer another governmental entity within the same
political subdivision. For instance, a city or municipality may use its local enforcement agency,
so long as the local law enforcement agency satisfies the criteria in Requirement R6. The third
party reviewer, however, must still be a third party and cannot be a division of the registered
entity that operates as a functional unit.
The Responsible Entity can select from several possible entities to perform the review:
•

An entity or organization with electric industry physical security experience and whose
review staff has at least one member who holds either a Certified Protection
Professional (CPP) or Physical Security Professional (PSP) certification.
In selecting CPP and PSP for use in this standard, the SDT believed it was important
that if a private entity such as a consulting or security firm was engaged to conduct
the third party review, they must tangibly demonstrate competence to conduct the
review. This includes electric industry physical security experience and either of the
premier security industry certifications sponsored by ASIS International. The ASIS
certification program was initiated in 1977, and those that hold the CPP certification
are board certified in security management. Those that hold the PSP certification are
board certified in physical security.

•

An entity or organization approved by the ERO.

•

A governmental agency with physical security expertise.

•

An entity or organization with demonstrated law enforcement, government, or
military physical security expertise.

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As with the verification under Requirement R2, Requirement R6 provides that the “review may
occur concurrently with or after completion of the evaluation performed under Requirement
R4 and the security plan development under Requirement R5.” This provision is designed to
provide applicable Transmission Owners and Transmission Operators the flexibility to work with
the third party reviewer throughout (i.e., concurrent with) the evaluation performed according
to Requirement R4 and the security plan(s) developed according to Requirement R5, which for
some Responsible Entities may be more efficient and effective. In other words, a Transmission
Owner or Transmission Operator could collaborate with their unaffiliated third party reviewer
to perform an evaluation of potential threats and vulnerabilities (Requirement R4) and develop
a security plan (Requirement R5) to satisfy Requirements R4 through R6 simultaneously. The
intent of Requirement R6 is to have an entity other than the owner or operator of the facility to
be involved in the Requirement R4 evaluation and the development of the Requirement R5
security plans and have an opportunity to provide input on the evaluation and the security plan.
Accordingly, Requirement R6 is designed to allow entities the discretion to have a two-step
process, where the Transmission Owner performs the evaluation and develops the security plan
itself and then has a third party review that assessment, or a one-step process, where the entity
collaborates with a third party to perform the evaluation and develop the security plan.

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Timeline

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Rationale
During development of this standard, text boxes were embedded within the standard to explain
the rationale for various parts of the standard. Upon BOT approval, the text from the rationale
text boxes was moved to this section.
Rationale for Requirement R1:
This requirement meets the FERC directive from paragraph 6 of its March 7, 2014 order on
physical security to perform a risk assessment to identify which facilities if rendered inoperable
or damaged could impact an Interconnection through instability, uncontrolled separation, or
cascading failures. The requirement is not intended to bring within the scope of the standard a
Transmission station or Transmission substation unless the applicable Transmission Owner
determines through technical studies and analyses based on objective analysis, technical
expertise, operating experience and experienced judgment that the loss of such facility would
have a critical impact on the operation of the Interconnection in the event the asset is rendered
inoperable or damaged. In the November 20, 2014 Order, FERC reiterated that “only an
instability that has a “critical impact on the operation of the interconnection” warrants finding
that the facility causing the instability is critical under Requirement R1.” The Transmission
Owner may determine the criteria for critical impact by considering, among other criteria, any
of the following:
•

Criteria or methodology used by Transmission Planners or Planning Coordinators in TPL001-4, Requirement R6

•

NERC EOP-004-2 reporting criteria

•

Area or magnitude of potential impact

Requirement R1 also meets the FERC directive for periodic reevaluation of the risk assessment
by requiring the risk assessment to be performed every 30 months (or 60 months for an entity
that has not identified in a previous risk assessment any Transmission stations or Transmission
substations that if rendered inoperable or damaged could result in instability, uncontrolled
separation, or Cascading within an Interconnection).
After identifying each Transmission station and Transmission substation that meets the criteria
in Requirement R1, it is important to additionally identify the primary control center that
operationally controls that Transmission station or Transmission substation (i.e., the control
center whose electronic actions can cause direct physical actions at the identified Transmission
station and Transmission substation, such as opening a breaker, compared to a control center
that only has the ability to monitor the Transmission station and Transmission substation and,
therefore, must coordinate direct physical action through another entity).
Rationale for Requirement R2:
This requirement meets the FERC directive from paragraph 11 in the order on physical security
requiring verification by an entity other than the owner or operator of the risk assessment
performed under Requirement R1.

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Guidelines and Technical Basis
This requirement provides the flexibility for a Transmission Owner to select registered and nonregistered entities with transmission planning or analysis experience to perform the verification
of the Requirement R1 risk assessment. The term “unaffiliated” means that the selected
verifying entity cannot be a corporate affiliate (i.e., the verifying entity cannot be an entity that
controls, is controlled by, or is under common control with, the Transmission owner). The
verifying entity also cannot be a division of the Transmission Owner that operates as a
functional unit. The term “unaffiliated” is not intended to prohibit a governmental entity from
using another government entity to be a verifier under Requirement R2.
Requirement R2 also provides the Transmission Owner the flexibility to work with the verifying
entity throughout the Requirement R1 risk assessment, which for some Transmission Owners
may be more efficient and effective. In other words, a Transmission Owner could coordinate
with their unaffiliated verifying entity to perform a Requirement R1 risk assessment to satisfy
both Requirement R1 and Requirement R2 concurrently.
Planning Coordinator is a functional entity listed in Part 2.1. The Planning Coordinator and
Planning Authority are the same entity as shown in the NERC Glossary of Terms Used in NERC
Reliability Standards.
Rationale for Requirement R3:
Some Transmission Operators will have obligations under this standard for certain primary
control centers. Those obligations, however, are contingent upon a Transmission Owner first
identifying which Transmission stations and Transmission substations meet the criteria
specified by Requirement R1, as verified according to Requirement R2. This requirement is
intended to ensure that a Transmission Operator that has operational control of a primary
control center identified in Requirement R1, Part 1.2 of a Transmission station or Transmission
substation verified according to Requirement R2 receives notice of such identification so that
the Transmission Operator may timely fulfill its resulting obligations under Requirements R4
through R6. Since the timing obligations in Requirements R4 through R6 are based upon
completion of Requirement R2, the Transmission Owner must also include notice of the date of
completion of Requirement R2. Similarly, the Transmission Owner must notify the Transmission
Operator of any removals from identification that result from a subsequent risk assessment
under Requirement R1 or the verification process under Requirement R2.
Rationale for Requirement R4:
This requirement meets the FERC directive from paragraph 8 in the order on physical security
that the reliability standard must require tailored evaluation of potential threats and
vulnerabilities to facilities identified in Requirement R1 and verified according to Requirement
R2. Threats and vulnerabilities may vary from facility to facility based on factors such as the
facility’s location, size, function, existing protections, and attractiveness of the target. As such,
the requirement does not mandate a one-size-fits-all approach but requires entities to account
for the unique characteristics of their facilities.
Requirement R4 does not explicitly state when the evaluation of threats and vulnerabilities
must occur or be completed. However, Requirement R5 requires that the entity’s security
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Guidelines and Technical Basis
plan(s), which is dependent on the Requirement R4 evaluation, must be completed within 120
calendar days following completion of Requirement R2. Thus, an entity has the flexibility when
to complete the Requirement R4 evaluation, provided that it is completed in time to comply
with the requirement in Requirement R5 to develop a physical security plan 120 calendar days
following completion of Requirement R2.
Rationale for Requirement R5:
This requirement meets the FERC directive from paragraph 9 in the order on physical security
requiring the development and implementation of a security plan(s) designed to protect against
attacks to the facilities identified in Requirement R1 based on the assessment performed under
Requirement R4.
Rationale for Requirement R6:
This requirement meets the FERC directive from paragraph 11 in the order on physical security
requiring review by an entity other than the owner or operator with appropriate expertise of
the evaluation performed according to Requirement R4 and the security plan(s) developed
according to Requirement R5.
As with the verification required by Requirement R2, Requirement R6 provides Transmission
Owners and Transmission Operators the flexibility to work with the third party reviewer
throughout the Requirement R4 evaluation and the development of the Requirement R5
security plan(s). This would allow entities to satisfy their obligations under Requirement R6
concurrent with the satisfaction of their obligations under Requirements R4 and R5.

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