Message-ID: <20664983.1075858702291.JavaMail.evans@thyme> Date: Wed, 26 Sep 2001 13:54:14 -0700 (PDT) From: dan.staines@enron.com To: dave.perrino@enron.com, l..nicolay@enron.com, richard.shapiro@enron.com, d..steffes@enron.com, linda.robertson@enron.com, john.shelk@enron.com, charles.yeung@enron.com, richard.ingersoll@enron.com, andy.rodriquez@enron.com, sarah.novosel@enron.com, donna.fulton@enron.com, ray.alvarez@enron.com, michael.roan@enron.com, luiz.maurer@enron.com, joe.connor@enron.com, steve.walton@enron.com, alan.comnes@enron.com, howard.fromer@enron.com, daniel.allegretti@enron.com, tom.hoatson@enron.com, thane.twiggs@enron.com, pat.shortridge@enron.com Subject: RE: NERC Statements on Impact of Security Threats on RTOs Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable X-From: Staines, Dan X-To: Perrino, Dave , Nicolay, Christi L. , Shapiro, Richard , Steffes, James D. , Robertson, Linda , Shelk, John , Yeung, Charles , Ingersoll, Richard , Rodriquez, Andy , Novosel, Sarah , Fulton, Donna , Alvarez, Ray , Roan, Michael , Maurer, Luiz , Connor, Joe , Walton, Steve , Comnes, Alan , Fromer, Howard , Allegretti, Daniel , Hoatson, Tom , Twiggs, Thane , Shortridge, Pat X-cc: X-bcc: X-Folder: \RSHAPIRO (Non-Privileged)\Shapiro, Richard\NERC X-Origin: Shapiro-R X-FileName: RSHAPIRO (Non-Privileged).pst Christi , I completely agree with Dave .In addition to the levels of redundancy he = states it is important to note that the Central Control Centers are more o= f a communication and dispatch hub but the actual control of the circuit b= reakers , transformers, phase angle regulators and voltage control devices= (the reliability backbone) resides within the "sub control centers " of the= Transmission Operators like Con Edison, Florida Power &Light etc etc..The= destruction of one of the major RTO control centers will not shut down tra= nsmission lines or trip generators off line .There would be loss of communi= cation to the region or local control centers and there may be some out of = merit generation moves but it would not be a disaster . With the redundanc= y of control centers, computers ,communications and data acquisition along = with the proper protocols and procedures the loss should not severely effe= ct the security or reliability of the transmission grid .This redundancy wi= ll be an important part of the RTO development but there is no valid reason= to slow up the present pace of progress because of this issue. I believe there are much more vulnerable areas within the Transmission grid= that NERC should be concerned about and address . I am open to continue th= is discussion off line . Dan =20 =20 -----Original Message----- From: =09Perrino, Dave =20 Sent:=09Wednesday, September 26, 2001 12:53 PM To:=09Nicolay, Christi L.; Shapiro, Richard; Steffes, James D.; Robertson, = Linda; Shelk, John; Yeung, Charles; Ingersoll, Richard; Rodriquez, Andy; No= vosel, Sarah; Fulton, Donna; Alvarez, Ray; Roan, Michael; Maurer, Luiz; Con= nor, Joe; Walton, Steve; Comnes, Alan; Staines, Dan; Fromer, Howard; Allegr= etti, Daniel; Hoatson, Tom; Twiggs, Thane; Shortridge, Pat Subject:=09RE: NERC Statements on Impact of Security Threats on RTOs Christi, The NERC statements clearly seem to indicate they feel threatened by the RT= O formation process and EISB. Frankly, nothing stated anywhere in the attachments hasn't already been tho= ught out and handled by the three ISOs in the East and the CAISO as well. = All four of these entities have fully functional back-up facilities in othe= r parts of their regions and NERC is fully aware of them. I would assume E= RCOT also has a fully functional, redundant control scheme in place as well= . In the case of NY there is another site physically apart from the main cont= rol center which has a fully redundant computer and communications system. = They have (or used to have) plans which in the event neither center is ava= ilable, can revert control back to the TOs (heaven forbid) until ISO perso= nnel can resume control of the grid. So they have 3 sets of redundancy, in= addition to radio and satellite communications if necessary. Earlier RTO West discussions all contained similar concerns and plans for r= edundancy and the DSTAR preliminary design documents also plan on redundanc= y. NERCs assertion that they would "slow-down" the RTO formation process i= s absurd (geez, it's going too slow now!!!).=20 Running distributed, synchronized computer networks is not rocket science..= .how do the folks at NERC explain the NYSE quick recovery from a ground zer= o attack? There was no report of crippling loss of financial information..= .at least that I am aware of. Even a small operation like APX operates the= ir systems using distributed computing and synchronized data. For NERC to use the NIMDA virus as a specific attack on the electrical grid= operation and the compromising of reliability is preposterous and the resu= lting "service denials" cited are probably refusal(s) of tags, which from w= hat I understand, the utilities probably cause much more self-inflicted hav= oc than this virus! The press release you refer to just confirms NERC's position of maintaining= status quo. Should we "call" NERC on these statements? The remarks made = in these public statements seem irresponsible. Kind Regards, Dave=20 -----Original Message----- From: Nicolay, Christi L.=20 Sent: Wednesday, September 26, 2001 9:11 AM To: Shapiro, Richard; Steffes, James D.; Robertson, Linda; Shelk, John; Yeung, Charles; Ingersoll, Richard; Rodriquez, Andy; Novosel, Sarah; Fulton, Donna; Alvarez, Ray; Roan, Michael; Maurer, Luiz; Connor, Joe; Walton, Steve; Comnes, Alan; Perrino, Dave; Staines, Dan; Fromer, Howard; Allegretti, Daniel; Hoatson, Tom; Twiggs, Thane; Shortridge, Pat Subject: FW: NERC Statements on Impact of Security Threats on RTOs Our NERC folks should be able to shed more light on why NERC is making stat= ements that on their face look anti-large RTO (the other emails and comment= s in these document look more like "this should be reviewed".) Do we (and other market participants) need to have a computer systems group= perform a study that includes redunancy issues, etc. to counter this? Cer= tainly, Pat Wood and Nora Brownell's testimony to Congress indicate that th= ey believe that large RTOs will bring more security and reliability (we hav= e included this in our SE RTO mediation comments.) -----Original Message----- From: Michael Reddy [mailto:Mreddy@epsa.org] Sent: Tuesday, September 25, 2001 4:09 PM To: acomnes@enron.com; Hawkins, Bernadette; Nersesian, Carin; Yeung, Charles; Nicolay, Christi L.; Fulton, Donna; Scheuer, Janelle; Hartsoe, Joe; Shelk, John; Jsteffe@enron.com; Noske, Linda J.; Robertson, Linda; Alvarez, Ray; Shapiro, Richard; Novosel, Sarah; Mara, Susan; Lindberg, Susan; Hoatson, Tom Subject: NERC Statements on Impact of Security Threats on RTOs MEMORANDUM TO: Legislative Affairs Committee Regulatory Affairs Committee NAERO Working Group FROM: Scott Weiner, Legislative Affairs Committee Chair Jim Steffes, Regulatory Affairs Committee Chair Mark Bennett, Senior Manager of Policy Donn Salvosa, Manager of Government Affairs DATE: September 25, 2001 RE: NERC Statements on Impact of Security Threats on RTOs The attached e-mail in Microsoft Word form contains statements that NERC ma= de during a recent meeting with members of the national press. The stateme= nts concern NERC's view of the implications of terrorist threats for FERC's= " Four RTO policy" set forth in its July 12th Order. The statements also = may bear upon the effort to establish a new standards setting organization,= particularly the possibility that NERC's responsibilities could be shifted= to EISB. Also attached is an article containing the views of R.J. Rudden = Associates, Inc. that discusses the risks associated with centralizing cont= rol center operations. Specifically, NERC representatives informed the press that on September 11 = "the grid was the target of an insidious cyber attack that shut down some f= acilities...from an information administration standpoint." They noted tha= t this resulted in service denials, although it is not clear whether they i= ndicated where or how much. This event was attributed to the so-called "NI= MBA virus". NERC's statements suggest a new strategy to preserve the role they've playe= d not only in security matters, but possibly other aspects pertaining to "r= eliability standards." They warn against any immediate transition to fewer= RTOs as envisioned in FERC's July 12th Order. Moreover, it is likely that= NERC will argue that, given its expertise and experience, recent events ma= ke transitioning to a new standards organization (EISB?) ill advised. =20 It is unclear what, if any, impact all this may have on RTO development, th= e legislative effort to establish a new reliability standards body or the N= ERC Board's consideration of pending reform proposals at its October meetin= g. However, we can expect security related issues to be included in future= discussions of these matters.=20 Please provide your reactions to the NERC statements to Mark Bennett at 202= -628-8200 or mbennett@epsa.org