February 27, 2020
Federal Energy Regulatory Commission
Kimberly D. Bose, Secretary
888 First Street, NE
Washington, DC 20426
RE: Docket No. EL20-21-000
Dear Ms. Bose,
Please consider this a Motion to Intervene for the purpose of filing comments in this docket. As an elected member of the New Hampshire House of Representatives, I represent constituents in Franklin and Hill, New Hampshire. I am a retired United States Air Force Officer and was the operational pilot for the B-2 during development. I am an engineer with extensive experience in nuclear effects and systems design. I also was heavily involved in the defense electronics industry in numerous special access programs.
The health and safety of my constituents, as well as the economy of the district I represent depends on the ability of the bulk power system to deliver electricity. This, in turn, depends on adequate and effective protection against physical attacks on the electric grid.
I am very disturbed by the allegations in this Complaint and the supplemental information filed by Mr. Michael Mabee on February 19, 2020. Mr. Mabee quotes a passage from CIP-14-2 (Physical Security) that indicates very few facilities are actually covered under this standard:
“The Standard Drafting Team (SDT) expects this population [facilities covered by the physical security standard] will be small and that many Transmission Owners that meet the applicability of this standard will not actually identify any such Facilities.” (CIP-14-2, Page 22.)
“Additionally, the SDT determined that it was not necessary to include Generator Operators and Generator Owners in the Reliability Standard.” (CIP-14-2, Page 23.)
Further, Mr. Mabee quotes an April 23, 2015 FERC order which states:
“Reliability Standard CIP‐014‐1 does not require responsible entities to assess the criticality of Bulk‐Power System facilities based on a simultaneous attack on multiple facilities.” (Order Denying Rehearing in Docket RM14‐15‐001. Page 4.)
If our generation facilities are not even covered by this standard, what protects us from a physical attack on multiple generation facilities? If very few of our transformers and none of our transmission lines are actually covered under the standard, what protects us from an attack on several of these unprotected facilities at once?
I do not believe the Commission can say that CIP-14-2, in its present state, offers sufficient protection if there is no consideration in the standard of the impact of simultaneous attack on multiple facilities. As we know, on September 11, 2001, the United States suffered a complex and well-coordinated physical attack against multiple locations. I am concerned that our electric grid is a target for such a coordinated physical attack.
A wide-scale blackout caused by a simultaneous attack on multiple bulk power system facilities poses a danger to all dependent critical infrastructures. Failure of our critical infrastructures from such an attack endangers lives, the economy and our national security. I am very concerned that the present physical security standard, CIP-14-2, may not adequately protect us against such a coordinated physical attack.
Given the bulk power system’s key role in enabling all 16 critical infrastructure sectors, I request the Commission undertake a review of CIP-14-2 and direct whatever improvements are necessary to provide effective protection for the bulk power system. Specifically, the Commission should consider the impact of a coordinated attack against multiple facilities including generation, transformers, control centers and transmission lines.
This issue needs the Commission’s immediate and urgent attention.
David K. Testerman
Criminal Law and Safety Committee
33 N. State Street, LOB 204
Concord, NH 03301