On February 20, 2020, FERC issued a notice of inquiry (“NOI”) to learn more about the potential benefits and risks of virtualization and cloud computing services in the bulk electric system operations. The NOI also seeks information about the barriers that exist in FERC-approved Critical Infrastructure Protection (“CIP”) Reliability Standards that impede the voluntary adoption of virtualization or cloud computing services.
As explained in the NOI, “virtualization” is the process of creating virtual versions of computer hardware to minimize the amount of physical computer hardware resources needed to perform various functions. Cloud computing is defined as a model for enabling convenient, on-demand network access to a shared pool of configurable computing resources.
FERC issued the NOI in response to comments made during FERC’s June 27, 2019 Reliability Technical Conference and the Department of Energy’s and FERC’s March 28, 2019 Security Investments for Energy Infrastructure Technical Conference.
Specifically, FERC seeks comments on four general topics, each of which are accompanied by various question prompts in the NOI: (A) scope of potential use of virtualization and cloud computing services (e.g. “which BES reliability operating services referenced above could be implemented in a virtualized environment?”); (B) potential benefits and risks associated with virtualization and cloud computing services (e.g. “what are the potential benefits associated with adopting virtualization for the BES reliability operating services?”); (C) potential impediments to adopting virtualization and cloud computing services (e.g. “how the CIP Reliability Standards could be augmented to address these challenges?”); and (D) potential use of new and emerging technologies in the current CIP standards framework (e.g. “whether the CIP Reliability Standards limit the ability to take full advantage of new and emerging technologies for BES reliability operating services.”).
FERC intends to use the record in this proceeding to determine if it should, pursuant to section 215(d)(5) of the Federal Power Act, direct NERC to develop modifications to the CIP Reliability Standards for the voluntary adoption of virtualization and cloud computing services by registered entities.
Initial comments are due 60 days after the date of publication in the Federal Register. Reply comments are due 90 days after publication in the Federal Register.
Click here to read the full NOI and the procedures for commenting.