Technical Feasibility Exceptions

**Deadline for Part A is January 31st!

A little background (and as much in layman's terms as possible)....

Back in March of 2009, NERC started creating an approach to catalog and verify exceptions to the NERC CIP standard. Mainly, this refers to very specific instances in the CIP standard that allow an entity to take exception because of technical feasibility or technical limitations. The Federal government wanted more accountability for this process, as these exceptions were seen by the government to be a way around complying with CIP security.

The basic idea behind a Technical Feasibility Exception (TFE) is that some equipment just can't support some of the CIP security controls. In these cases, utilities are required to document the situation and send it to NERC or their regional entity for review and approval.

Most TFEs are obvious. For instance, PLCs don't have anti-virus, disabling ports on printers is not always possible, and certain software crashes badly when you change certain passwords. These will likely be approved. Others are more complicated, and depend on system interactions as well as other reliability concerns.

Owners are required to fill out and submit TFEs for situations where they can't meet CIP requirements. There are two parts to this process: a Part A and a Part B.

Part A is a notification of intent to file a TFE. This goes directly to the Regional Entity via Electronic Submission (often the same way as your vegetation management reports). It's a simple form (see the bottom for links). Check with your Regional Entity for more details, as the process differs between regions.

Part B is the detailed evidence for the TFE. Some of this may be filed, but for the most part it must be present at the Owners location for reviewing by the Regional Entity and/or NERC.

When submitting TFEs, consider the sensitivity of the information. For sensitive information, make sure to mark submissions "Confidential" according to Section 1500 of the Rules of Procedure.

**Deadline for Part A is January 31st!

More details on TFEs:
1. NERC Rules of Procedure - (Look for Appendix 4D, and this also includes the Part A form)
2. Texas Regional Entity CIP FAQ
3. SERC Posting Regarding TFEs