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Mounting Compliance Challenges Under New CIP Standards

May 24, 2012
Reprinted with permission from Energy Law360

New criteria approved in April 2012 by the Federal Energy Regulatory Commission (FERC) will impose cybersecurity standards on additional generating, transmission and other facilities critical to the bulk power system's reliability. But complying with these standards by the July 2014 effective date is only part of the challenge presented by Version 4 of the North American Electric Reliability Corporation (NERC) cybersecurity standards, known as the critical infrastructure protection (CIP) reliability standards. Regulated entities must also prepare for Version 5, which NERC must file by March 31, 2013, and the real possibility that Version 4 compliance efforts will be all for naught if the new cybersecurity standards are substantially revised before Version 4 ever goes into effect.

Sutherland attorneys Daniel E. Frank, Meghan R. Gruebner and Jennifer J. Kubicek discuss the implications of CIP Version 4 and the development of CIP Version 5 in "Mounting Compliance Challenges Under New CIP Standards," published May 24, 2012 in Energy Law360.

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