As a service to our members, EnergySec will assist with, coordinate, and/or submit formal Requests for Interpretation (RFI) of the NERC CIP standards. The RFI process is available to Registered Entities to request formal, legally binding clarification where significant uncertainty exists with respect to the meaning of a requirement. Although the RFI process should not be used lightly, there will be situations which warrant its use.
EnergySec staff and leadership has experience writing RFIs, and has successfully shepherded multiple RFIs through the process. Well are well-positioned to assist member entities with the evaluation of potential RFI situations, drafting of the request where needed, and interacting with NERC and Interpretation Drafting Team (IDT) throughout the process. Additionally, coordination of RFIs between multiple entities adds credibility to the request and promotes efficient use of the process and industry resources.
EnergySec services in this area are complimentary to our members and include the following:
EnergySec staff is available to review situations which may be appropriate for an RFI. In many cases we may be able to provide clarification based on current unofficial guidance or audit approaches published by NERC or the Regions. Where uncertainty still exists, we can recommend whether an RFI is an appropriate approach.
EnergySec staff can provide coordination between entities with common interpretive issues. Coordination, and potential joint filing of RFIs, can add emphasis to the importance of a request while also reducing potential duplicate effort and waste of scarce resources.
EnergySec’s NERC CIP experts have deep experience with the standards and specific experience with the RFI process. We can ensure that RFIs are written to effectively express the underlying issues and improve the likelihood that any RFI responses will address the issue at hand.
EnergySec staff can submit RFIs and handle all communication between NERC and the IDT. Interested entities can be included in all interactions to whatever extent desired. The use of EnergySec staff provides additional expertise as well as a neutral party to help work through any potential issues which arise during the process.
To request further information or assistance with a potential RFI, contact firstname.lastname@example.org, or any of our staff members.