Background

According to the FERC news release, the 2020 global supply chain attack involving the SolarWinds Orion software demonstrated how attackers can "bypass all network perimeter-based security controls traditionally used to identify malicious activity and compromise the networks of public and private organizations."  Thus, FERC determined that current CIP Reliability Standards focus on prevention of unauthorized access at the electronic security perimeter and that CIP-networked environments are thus vulnerable to attacks that bypass perimeter-based security controls.  The new or modified Reliability Standards ("INSM Standards") are intended to address this gap by requiring responsible entities to employ INSM in certain BES Cyber Systems.  INSM is a subset of network security monitoring that enables continuing visibility over communications between networked devices that are in the so-called "trust zone," a term which generally describes a discrete and secure computing environment.  For purposes of the rule, the trust zone is any CIP-networked environment.  In addition to continuous visibility, INSM facilitates the detection of malicious and anomalous network activity to identify and prevent attacks in progress.  Examples provided by FERC of tools that may support INSM include anti-malware, intrusion detection systems, intrusion prevention systems, and firewalls.   

New or Modified Reliability Standards

The INSM Standards will apply to all high-impact BES Cyber Systems and medium-impact BES Cyber Systems with external routable connectivity, defined as the ability to access a BES Cyber System from outside of its associated electronic security perimeter.FERC拒绝为即将实现的标准设定执行时间框架,代之以指令NERC提交建议书时推荐执行期,因此责任实体实施INSM的最后期限可能是未来数年 。

规则下INSM标准必须:

• (1)解决责任实体开发CIP网络环境网络流量基线的需要;

• (c) Implementing measures to minimize the likelihood of an attacker removing evidence of their tactics, techniques, and procedures from compromised devices.

Feasibility Study

Within 12 months of the final rule, NERC must also submit a report that studies the feasibility of implementing INSM within medium-impact BES Cyber Systems without external routable connectivity and all low-impact BES Cyber Systems, which are not subject to the INSM Standards.

FERC has emphasized that the commissioned feasibility study should include a determination of:

(1) The ongoing risk to the reliability and security of the Bulk-Power System posed by low and medium-impact BES Cyber Systems that will not be subject to the INSM Standards!并

供应链链DOE可直接提供金融支持以拓展变压器或关键材料输入量的国内制造能力或可承诺购买量变压器向厂家提供需求确定性。 除变压器和电网组件外,RFI还覆盖下列技术:太阳能光电隔热素材电解器、白金类金属和净氢燃料电池东区2022年11月30日 //www.ludikid.com/2022/08/ferc-proposes-major-changes-to-generator-interconnection-process/ Mark Perlis和Jonathan Wright 52022年8月5日Frii 电网 FERC 生成器互连 网格现代化 大生成器互连程序 通知拟议规则制定 //www.ludikid.com/?p=7889 p对齐='Center'##p>联邦能源监管委员会最近发布建议规则设计通知以改革生成器互连过程拟议的规则旨在加速新生成器和存储器与电网连接并清除快速互连积存,主要是可再生存储资源积存提示提示Continue Reading… s/www.ferc.gov/media/rm2214-000拟规则旨在加速新生成器和存储器与网格连接并清除快速互连积存,主要是可再生和存储资源。

Driven by the entry of renewable generation resources locating far from load centers and the new demands placed on the grid by their differing characteristics, the Federal Energy Regulatory Commission (FERC) launched a comprehensive review of its policies regarding regional transmission planning, interconnection and cost-allocation.  In an Advance Notice of Proposed Rulemaking (ANOPR), the agency requested public comments on its current policies and offered potential areas for reform with a view toward anticipated future generation.  According to FERC Chairman Richard Glick, "(a) piecemeal approach to expanding the transmission system is not going to get the job done.We must take steps today to build the transmission that tomorrow's new generation resources will require."

This initiative is likely to result in specific proposals from FERC and ultimately reform of its rules and policies that could substantially change how the electric grid is planned and paid for.  Accordingly, the ANOPR should be of interest to any company with a current or anticipated interest in, or use of, grid facilities.

This is the second initiative in as many months that FERC has taken a big step toward addressing the kind of grid needed for renewable generation  As discussed in a prior post to the blog, last month FERC established a Joint Federal-State Task Force on Electric Transmission with state and local regulatory agencies to address barriers to transmission planning and development, opportunities for states to coordinate on regional transmission solutions, and barriers to interconnecting new resources.

The ANOPR

After providing a comprehensive discussion of its current policies regarding transmission planning, cost allocation and interconnection, FERC says "it is now appropriate to examine whether the existing regional transmission planning and cost allocation and generator interconnection processes adequately account for the transmission needs of the changing resource mix."  Accordingly, the ANOPR identifies the following major aspects as potential areas for reform.关于每一方面,ANOPR请求评论当前政策的适当性并同时建议潜在的改革。

This is the twenty-fourth in our series, "The ABCs of the AJP."

In 2020 alone, the United States suffered 22 separate extreme weather and climate-related disasters that each caused at least $1 billion in damages, for a total of more than $100 billion in losses.  That staggering statistic is not an anomaly, as climate change continues to result in more and more extreme weather events every year.  For example, the Texas freeze that rocked the state earlier this year and killed more than one hundred people, also shut down the state's significant petrochemical industry, disrupting supply chains nationwide, and caused an estimated $80 billion to $130 billion in direct and indirect economic losses.数以百计的死亡者为 < a hrefss/www.npr.org/2021/07/climbs-in-crips-northWest/

Given the escalating human and economic costs of extreme weather events, it is no surprise that the Biden Administration's American Jobs Plan (AJP) prioritizes climate resiliency, a topic which has also been covered in a prior blog post.  Significantly, the AJP pledges that: "Every dollar spent on rebuilding our infrastructure during the Biden administration will be used to prevent, reduce, and withstand the impacts of the climate crisis."  The AJP also proposes to spend $50 billion on investments to specifically improve the resiliency of the nation's infrastructure, highlighting the importance of protecting critical infrastructure and services, defending vulnerable communities, and "[m]aximiz[ing] the resilience of land and water resources to protect communities and the environment."

As for protecting vulnerable communities, the AJP points out that "[p]eople of color and low-income people are more likely to live in areas most vulnerable to flooding and other climate change-related weather events" and "[t]hey also are less likely to have the funds to prepare for and recover from extreme weather events."  To improve resiliency for those communities most vulnerable "physically and financially to climate-driven disasters", the AJP proposes increased investments through existing programs, such as FEMA's Building Resilient Infrastructure and Communities program and HUD's Community Development Block Grant program, new initiatives at the Department of Transportation, as well as "a bipartisan tax credit to provide incentives to low- and middle-income families and to small businesses to invest in disaster resilience, and transition and relocation assistance to support community-led transitions for the most vulnerable tribal communities."

Separately, the AJP would provide $500 million in grants and loan funds to renovate tens of thousands of multifamily homes to make them more resilient to extreme weather events.

Finally, the AJP proposes investing in nature-based resiliency, such as by restoring "our lands, forests, wetlands, watersheds, and coastal and ocean resources", as a means of wildfire and drought mitigation, among other goals.  The Administration also suggests that such restoration and resilience project funds would follow the guidelines of the proposed Outdoor Restoration Force Act (S.近些年来,人们更加关注自然基础建设的潜在利益,值得注意的是,美国土木工程师学会首次使用s/informstructioncard.org/solups/reslience/历经数年研究分析 来自世界各地的专家 今年夏美Army Corps of Engineers is set to release first-of-their-kind guidelines for nature-based resilience projects.

Beyond the AJP, protecting against extreme weather has been a priority of the Biden Administration from the beginning.  A few days into his presidency, President Biden signed a sweeping climate Executive Order which, among other things, directed federal agencies to develop climate resiliency plans.  More recently, on May 24, 2021, the Administration announced a plan to invest $1 billion in protecting communities through FEMA's Pre-Disaster Building Resilient Infrastructure and Communities program.  As with other actions taken by the Administration, this increased investment "seeks to categorically shift the federal focus from reactive disaster spending and toward research-supported, proactive investment in community resilience so that when the next hurricane, flood, or wildfire comes, communities are better prepared."  Along with the increased funding, the Administration also announced plans to develop and launch "a new NASA mission concept for an Earth System Observatory" to better forecast and monitor natural disasters.

At this point, it is unclear whether or how Congress will act to implement the Biden Administration's proposals to protect against extreme weather.  However, there are some signs of bipartisan interest in such legislation.  For example, after the Texas freeze in early 2021, a bipartisan group of members of the Texas congressional delegation introduced the Power On Act (S.1432 帮助保护电网基础设施不受极端天气影响。此外,2019年,参议院环境与公共工程委员会一致通过了2019年美国交通基础设施法(sgp/crs/misc/IF11300.pdf>$100dm/a问题很可能成为双党优先处理点,特别是当德克萨斯冻结事件在全国各地变得司空见惯时。 双党重心对极端天气事件进行保护后,所有美国人和企业都应从更多保护中受益,避免事件造成的损害、损失、中断和人类代价。

This is the twenty-first in our series, "The ABCs of the AJP."

President Biden's American Jobs Plan (AJP) sets an ambitious goal of "achieving 100 percent carbon-free electricity by 2035."  To accomplish this, the AJP proposes significant investments in grid modernization, transmission infrastructure, offshore wind, and energy storage, as detailed by our prior posts.  Whether these investments – carrots, if you will – will be sufficient to drive down emissions in all states and achieve the 2035 target, in the absence of an enforceable clean electricity standard (CES), remains uncertain.  Equally uncertain is the pathway for Congress to enact a CES.

A CES would mandate that electric utilities increase the amount of zero-carbon power they deliver to their customers on a gradually increasing schedule, until the target is achieved.  Such "sticks" would not only assure continued addition of renewables to the grid, but would also provide a strong incentive for the preservation of existing zero-carbon power sources at risk of retirement, such as nuclear.

A CES has been described as the backbone of President Biden's climate policy, given the role that the electricity sector is expected to play in decarbonizing the broader economy through electrification of transportation and buildings.  Yet the pathway to enacting a CES as part of an infrastructure package may be narrowing: The Bipartisan Infrastructure Framework that the President announced he would support last week includes no CES.  And whether a CES could be enacted through the budget reconciliation process is subject to considerable debate.

Existing CES bills in Congress seem unlikely to gain enough support to overcome a filibuster.

• The CLEAN Future Act, which would aim to achieve the Administration's goal of 100% zero-emission electricity by 2035, may be too ambitious to gain support of 60 senators.
• The Clean Energy Future Through Innovation Act, which targets an 80% reduction in power sector emissions by 2050, is likely to be dismissed by many within the Democratic caucus as not ambitious enough and because its targets would not go into effect until the DOE Secretary certifies that cost-effective market penetration of advanced clean power generation technologies has occurred, with no date certain.

Given the narrow chances for a true CES to be enacted by Congress, some suggest that the Administration may need a "plan B" to achieve its power-sector decarbonization target, either through EPA regulation of power plants or through a reconciliation-proof approach to a CES, in which the government would spend money to encourage clean generation (more carrots), without any enforceable mandate in place (no sticks).

Indeed, the AJP suggests that a CES could be established by executive action alone, declaring that, "President Biden will establish an Energy Efficiency and Clean Electricity Standard (EECES)," with no mention of a role for Congress.  Yet the experience of the Obama Administration, which had its centerpiece Clean Power Plan put on hold by the Supreme Court and then repealed by the Trump Administration, may leave both the Biden-Harris Administration and the electricity sector seeking a more durable policy.

And, despite a decision by the D.C.Circuit on the eve of the inauguration, striking down the Trump Administration's repeal of the Clean Power Plan and providing the incoming EPA Administrator Michael Regan what he called a "clean slate" to consider how to reduce emissions from the power sector, EPA recently categorized a new set of emission guidelines for power plants as a long-term action, meaning it is unlikely to move forward with a proposal in the near-term.

With total spending included in the Bipartisan Infrastructure Framework scaled down to $1.2 trillion from the AJP's proposed $2.3 trillion, some Democrats have said they will not support it, unless coupled with a broad reconciliation package.  The President himself had to walk back initial remarks, which suggested he would not sign the bipartisan deal unless it came to his desk with a reconciliation bill that fills in its gaps.  While that clarification appears to have satisfied key architects of the bipartisan deal for the time being, maintaining both that bipartisan support and the simple majority needed to pass a broader package through reconciliation could prove challenging.

The electricity sector is in the midst of a rapid transformation due to the rapidly declining costs of renewable and storage technologies, the low price of natural gas and customers' increasing demand for clean power.  These market forces so greatly outpaced projections made just a few short years ago that the Clean Power Plan's 2030 goal for the electricity sector was achieved a decade in advance, even though it never went into effect.  While this may beg the question of whether mandatory standards are even necessary if market forces are moving in one inexorable direction, utilities favor certainty due to their long-term planning horizons.  And that certainty may be lacking if any infrastructure package includes only a few carrots and no sticks.

FERC established the Task Force pursuant to Section 209(b) of the Federal Power Act, a rarely-invoked provision that authorizes FERC to confer with state commissions "regarding the relationship between rate structures, costs, accounts, charges, practices, classifications, and regulations of public utilities subject to the jurisdiction" of such state commissions and FERC.  The June 17 order noted that transmission-related issues were ripe for federal-state coordination and cooperation given the respective authority of federal and state regulators and the resulting processes that transmission developers must successfully navigate.

The Task Force will be comprised of all five FERC commissioners as well as representatives from 10 state commissions, who will serve one-year terms, not to exceed three consecutively, in an advisory capacity.FERC请求NARUC向FERC提交10国委代表提名表(NERUC区域有2名代表)至7月17日收到NARUC提名后,FERC将发布后续命令,列出工作队成员及其作用,并确定第一次公开会议的时间和地点。

617命令中还包含问题说明,列出工作队可能考虑的专题,包括:(1) 识别阻碍规划和开发实现联邦和州政策目标所必要的最优传播的障碍以及潜在解决方案探索国家自愿协调的机会以确定、规划并开发区域传输解决方案并(3)审查通过FERC辖区互连进程高效快捷地连接新资源的障碍,以及解决这些障碍的潜在方法特别工作组就这些题目开展工作后,可向FERC建议可能修改其条例并开发记录供FERC和/或国家委员会程序使用。

As discussed on our previous post on grid modernization, new transmission lines must be installed to allow high-capacity, long-distance power transmission, so that renewable energy can be efficiently transmitted from remote areas where it is plentiful to more densely populated locations where it is needed.

Here, we explore how the AJP's aim of securing investment for development of transmission infrastructure may advance a number of additional objectives:

• It can help bridge the physical and jurisdictional lines drawn between the Nation's regional power markets.
• It can improve the resiliency of the grid to the reliability threats posed by increasingly extreme weather events.
• And it can help stitch together the historical opposition between environmental and labor interests.

Power Lines, Political Lines, and Linkages

The contiguous U.S.eia.gov/todayinEnergy/detail.php?id=27152基本分离网格连接点很少,只能互传递小量能量The boundaries at which the grids abut (and minimally connect) are known as "seams."

Ongoing research from the Department of Energy's (DOE) National Renewable Energy Lab (NREL) suggests that fortifying these seams would provide substantial economic and environmental benefits, making it possible, for example, for solar power from the desert southwest to meet peak electricity demand in the northeast and then support similar demand peaks at later times in the west.

While NREL has yet to finalize its seams study, reportedly due to the prior administration's efforts to downplay those benefits, other studies have similarly projected tremendous return on investments in grid integration and improved power transmission.

• According to one such study, integrating the Nation's grids and installing high-voltage direct-current (DC) transmission lines – which can transmit energy over long distances more effectively than the alternating current (AC) lines that dominate the current grid – has the potential to save consumers over $47 billion annually.

In spite of the obvious benefits associated with a better-connected grid, overcoming the physical and jurisdictional boundaries separating the three interconnections will not be easy.

In particular, Texas has historically preserved its independence from oversight of the Federal Energy Regulatory Commission (FERC) by not significantly participating in interstate energy transmission.

That independence may be increasingly difficult to defend, however, in the aftermath of the failure of much of the Texas grid operated by the Electric Reliability Council of Texas (ERCOT) during this past February's extreme winter storm.

• Cities like El Paso, which are not part of ERCOT, fared relatively well, because they were able to receive power from neighboring balancing authorities and power markets.
• But the major metropolitan areas of Houston and Dallas-Fort Worth suffered catastrophic power losses because they were limited to the supply within ERCOT, which was designed to meet peak demand on a hot summer's day and could not keep up with the unprecedented winter demand.

It should come as no surprise, then, that the AJP's argument in favor of spending billions of dollars to improve our Nation's transmission infrastructure leads with a description of the Texas outages and prior research indicating that weather-related power outages cost the U.S.最大达每年700亿美元经济量。