It seems like every other post I write nowadays starts with something I read in the weekly EnergySec newsletter. Today’s post was prompted by speculation in this week’s newsletter that, due to yesterday's FERC action pushing back the CIP v5 compliance date by three months, some other CIP compliance dates for the v5 or the v6 standards might be pushed back, thus leading to even more confusion than currently reigns (if indeed such a thing is possible!).
On reading this, I immediately noted that there is no way the v6 implementation dates will be affected by this move, since those dates don’t depend at all on v5, and FERC only moved the main v5 date. As for the v5 dates themselves, there were only two anyway (vs. about 12 compliance events in v6, which are clustered among three dates): April 1 (now July 1), 2016 for High and Medium requirements, and April 1, 2017 for the one Low impact requirement in v5, CIP-003-5 R2.
These two dates were set independently of each other in the v5 Implementation Plan, so the fact that the High/Medium date is moved back three months doesn’t mean anything for the Low date. In fact, the Low date for v5 is meaningless, since CIP-003-5 R2 will be superseded by CIP-003-6 R2 – which comes into effect the same date, April 1, 2017.
To reflect this new change, I have changed the post I did in December with a revised compliance schedule. That post was prompted by the fact that FERC hadn’t approved v6 in December, meaning the v6 date was moved back to July 1. Of course, it was because that date is now July 1 that FERC yesterday agreed to move the v5 date to coincide with it. I’m tempted to say this will be the last change in the v5/v6 compliance dates, but I would have said the same thing in December.
The views and opinions expressed here are my own and don’t necessarily represent the views or opinions of Deloitte Advisory.