170 FERC ¶ 61,109

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability Corporation Docket No. RD20-2-000

ORDER DIRECTING INFORMATIONAL FILINGS REGARDING 

NERC STANDARD DRAFTING PROJECTS

(Issued February 20, 2020)

1. Pursuant to section 215 of the Federal Power Act (FPA),1 the Commission directs 

the North American Electric Reliability Corporation (NERC) to submit an informational 

filing describing the activity of two NERC critical infrastructure protection (CIP) 

standard drafting projects pertaining to virtualization and cloud computing services. 

Specifically, NERC should submit a schedule for Project 2016-02 (Modifications to CIP 

Standards) and Project 2019-02 (BES Cyber System Information Access Management) 

(collectively, NERC Projects). Each schedule should include the current status of the 

project, interim target dates, and the anticipated filing date for new or modified 

Reliability Standards. NERC is directed to submit the informational filing within 30 days 

of the date of issuance of this order. In addition, we direct NERC to file quarterly status 

updates, on an informational basis, until such time as new or modified Reliability 

Standards are filed with the Commission.

I. Background

A. Project 2016-02 – Modifications to CIP Standards

2. NERC initiated Project 2016-02 in 2016 to address a directive in Order No. 822 

regarding the protection of transient electronic devices used at low impact BES Cyber 

Systems.2 The standard authorization request for the project that defines the scope of the 

drafting project includes matters beyond the Order No. 822 directive, including revisions 

 1 16 U.S.C. § 824o (2018). See also 18 C.F.R. § 39.2(d) (2019) (the electric 

reliability organization shall provide the Commission information as necessary to 

implement section 215 of the FPA).

2 Revised Critical Infrastructure Protection Reliability Standards, Order No. 822, 

154 FERC ¶ 61,037, at P 32, order denying reh’g, Order No. 822-A, 156 FERC ¶ 61,052

(2016).
Docket No. RD20-2-000 - 2 -

to support the use of virtualization technologies by registered entities as compatible with 

the CIP Reliability Standards.

3

B. Project 2019-02 – BES Cyber System Information Access Management

3. NERC initiated Project 2019-02 in 2019 in response to an industry standard 

authorization request. The standard authorization request identified a need to enhance 

bulk electric system reliability by creating increased choice, greater flexibility, higher 

availability, and reduced‐cost options for responsible entities to manage their BES Cyber 

System Information. Specifically, Project 2019-02 is intended to facilitate the use of 

third‐party data storage and analysis systems, in part by clarifying the minimum 

protections expected when a responsible entity utilizes third‐party data management 

solutions (e.g., cloud computing services).4

II. Discussion

4. The Commission recognizes that the NERC Projects are ongoing and that 

substantial progress has been made by the standard drafting teams. As discussed in the 

Notice of Inquiry issued by the Commission regarding virtualization and cloud 

computing services, we are also aware of industry’s interest in ensuring that the 

Reliability Standards do not unnecessarily impede the adoption of new technologies that 

could contribute to a more efficiently planned and operated Bulk-Power System.5

 

5. Given the potential importance of virtualization and cloud computing services, 

pursuant to section 215 of the FPA, the Commission directs NERC to submit an 

informational filing to update the Commission on the progress of Project 2016-02 and 

Project 2019-02. In particular, NERC should submit a schedule for each NERC Project

that includes the current status of the project, interim target dates, and the anticipated 

filing date for new or modified Reliability Standards. NERC should submit the 

informational filing within 30 days of the date of issuance of this order. In addition, the 

Commission directs NERC to file quarterly status updates, on an informational basis,

starting 120 days from the date of issuance of this order, until such time new or modified

Reliability Standards are filed with the Commission.

 3 See North American Electric Reliability Corp., Reliability Standards Under 

Development, https://www.nerc.com/pa/Stand/Pages/Standards-UnderDevelopment.aspx.

4 See id.

5 Virtualization and Cloud Computing Services, Notice of Inquiry, 170 FERC 

¶ 61,110 (2020).
Docket No. RD20-2-000 - 3 -

The Commission orders:

(A) NERC is directed to make an informational filing for Project 2016-02 and 

Project 2019-02 within 30 days of the date of issuance of this order, as discussed in the 

body of this order.

(B) NERC is directed to file quarterly status updates on Project 2016-02 and

Project 2019-02, on an informational basis, starting 120 days from the date of issuance of 

this order, as discussed in the body of this order.

By the Commission. 

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.