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Commissioner Tony Clark Statement
Docket No. RM14-15-000
Item No. E-8

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Physical Security Reliability Standard NOPR

“In recent years and months, the Commission has continued its efforts to prepare for and reduce threats to the reliability of the bulk power system. The Commission has specifically engaged in the areas of vegetation management, reductions of human error through increased training, situational awareness, cybersecurity, and geomagnetic disturbances, to name a few.

“Today, the Commission addresses yet another potential threat to the reliable supply of electricity: physical attacks on utility infrastructure.

“Today’s issuance of a Notice of Proposed Rulemaking and the work of NERC up to this point are good first steps. I would emphasize, however, these are just first steps.

“In comments about the efforts undertaken to date, some have noted that the proposed standard would not provide enough visibility across the interconnection given that the identification of facilities would be done as a “bottom-up” exercise. I believe there is a grain of truth in those concerns.

“I encourage all stakeholders to view this as an iterative process that will continue to be improved. I view our proposed modifications and informational filings as avenues for further discussion and development to ensure that total grid awareness is considered when selecting assets to be further protected by enhanced physical security.”