UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Joint Staff White Paper on)

Notices of Penalty Pertaining to)Docket No. AD19-18-000

Violations of Critical Infrastructure)

Protection Reliability Standards)

ISO/RTO COUNCIL’S MOTION IN SUPPORT OF MOTION FOR EXTENSION OF
TIME TO FILE COMMENTS

The ISO/RTO Council (“IRC”)1 files in support of the motion for extension of time filed
by the Edison Electric Institute (“EEI”), the American Public Power Association (“APPA”), the
National Rural Electric Cooperative Association (“NRECA”), the Large Public Power Council
(“LPPC”), the Transmission Access Policy Study Group (“TAPS”), the Electric Power Supply
Association (“EPSA”), and the Electricity Consumers Resource Council (“ELCON”), on behalf
of their respective members (collectively, the “Joint Associations”), for an additional 30 days, until
October 27, 2019, to file comments in response to the Federal Energy Regulatory Commission
(“FERC”)/North American Electric Reliability Corporation (“NERC”) Joint Staff White Paper on
Notices of Penalty for Violations of NERC CIP Standards (“White Paper”) issued in the above-

The IRC comprises the Alberta Electric System Operator (“AESO”), the California
Independent System Operator Corporation (“CAISO”), the Electric Reliability Council of Texas, Inc. (“ERCOT”), the Independent Electricity System Operator (“IESO”), ISO New England Inc. (“ISO-NE”), the Midcontinent Independent System Operator, Inc. (“MISO”), the New York Independent System Operator, Inc. (“NYISO”), PJM Interconnection, L.L.C. (“PJM”), and the Southwest Power Pool, Inc. (“SPP”). AESO and IESO are not subject to the Commission’s jurisdiction. Therefore, AESO and IESO are not joining these comments. Individual IRC members may also file separate comments.

referenced docket, and for a shortened comment period on the Joint Association’s motion. Comments on the White Paper are currently due September 26, 2019.

I.COMMENTS

On August 27, 2019, the Commission issued the FERC/NERC White Paper.2 In the White
Paper, FERC and NERC staff proposed, for the first time, public disclosure of entity names,
standard(s) violated, and penalty amounts, for settlement agreements and for matters handled
pursuant to the Find, Fix and Track program and the Compliance Exception program. This
proposal marks a significant change in how FERC and NERC propose to handle public disclosure
of resolutions of CIP violations at all violation levels. Because this is a significant change, the
IRC supports the request to extend the deadline to file comments by 30 days submitted by the Joint
Associations, to afford commenters the opportunity to give this proposal full consideration and
provide the Commission with thoughtful comments regarding this new proposal.

II.CONCLUSION

The IRC supports the Joint Associations’ request for a 30-day extension of time, until

October 27, 2019, to provide comments in this docket.

Respectfully submitted,

____________________ Maria Gulluni

Vice President and General Counsel Margoth R. Caley

Senior Regulatory Counsel

ISO New England Inc.

One Sullivan Road

Holyoke, Massachusetts 01040 mcaley@iso-ne.com

____________________

Robert E. Fernandez, General Counsel Raymond Stalter,

Director of Regulatory Affairs
Carl Patka, Assistant General Counsel Christopher Sharp,

Senior Compliance Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, New York 12144 csharp@nyiso.com

____________________ Chad V. Seely

Vice President and General Counsel Nathan Bigbee

Assistant General Counsel Brandon Gleason

Senior Corporate Counsel

Electric Reliability Council of Texas, Inc.

7620 Metro Center Drive Austin, Texas 78744

nathan.bigbee@ercot.com

Dated: September 17, 2019

____________________ Craig Glazer

Vice President-Federal Government Policy James M. Burlew Senior Counsel

PJM Interconnection, L.L.C.

Suite 600

1200 G Street, N.W. Washington, D.C. 20005 202-423-4743

craig.glazer@pjm.com james.burlew@pjm.com ____________________ Paul Suskie

Executive Vice President, Regulatory Policy & General Counsel

Southwest Power Pool, Inc.

201 Worthen Drive

Little Rock, Arkansas 72223-4936 psuskie@spp.org

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding.3

Dated at Carmel, Indiana this 17th day of September, 2019.

/s/ Julie Bunn

Julie Bunn

Midcontinent Independent System Operator, Inc.

720 City Center Drive

Carmel, Indiana 46032

Telephone: (317) 249-5400

18 C.F.R. § 385.2010 (2015).