2. The FERC 725 B, Reliability Standards for critical infrastructure is required to
implement the statutory provisions of section 215 of the Federal Power Act,
The responsible entities designated a Reliability Standard. I am urging the
Commission to rule this on a case by case basis that should not disqualify the standard
because of a criminal record due to the extraordinary circumstances, from access to
critical cyber assets, not being aware of the situation, Hence the reliable entities in this
region didn't expect or proceed cautiously and overlooked the Reliability standard and
determination and competitive nature, and have been put in with a limited and
disinformation and strategically had the Reliability standard suppressed, by provisions
of the mental health act and other constraints, holds that was in consented. If
consulted, participation would have still occurred, it would be the only alternative , to
help Bulk Power System from becoming congested and increasing the burden on other
systems. The process to achieve a good Reliability Standard can be achieved without
manipulating the electricity market that have resulted in unjust and spikes in
electricity costs that are really unreasonable, to be specific the BPA, OIBDC, Fortis
BC_NK'Mip CPCN-Exhibit C1-78 and application and project For Nk'Mip substation &
Transmission line. The right away incentive agreement jointly signed between the
responsible entities. So an exception and a justified risk finding that Standards have
been violated while waiting for an official determination the inequities of the
framework are self-evident. Please excuse the recalcitrance but it was done so the
decisions made by the regional entity's would be subject to an appellate process, akin
to what is described in rule 410 of the NERC, and would like the commission to
consider appeal the decisions made by coordinators, operators, or balancing authority
and the delegation, to clarify that ERO with respect to the content, of the proposed
standard or modification Reliability standard, and technical expertise of the regional
entity organized on a interconnection-wide basis of the States and Provinces. If a
notice of penalty and record of proceedings is not been initiated please let this also be
a complaint that the, commission may take into consideration on a decision that will
defer the user or owner of bulk power system in the region to not engage in any
practices that constitute any more violations of the Reliability standard, and, any
penalty imposed under the subsection will bare a reasonable relation to the
seriousness of the violation and will consider the user, owner, operator to remedy the
violations in a timely manner.
Reliability Standards on certain CIP Standards registered with low impact assets may
need to be reviewed to reflect the actual burden and be adopted to a medium high
impact. Reported by ICS-CERT, this new kind of malware campaign is based on the
injection of malware while the product or service remains in control of the hardware
software vendors prior to delivery and specialized systems such as industrial process
control systems, telephone switching, private branch exchange, integrity, or the
controlled available information, And a operational exercise Dr. Ross and Stephanie
shankled, tests and elevates the Reliability standard.
If there is anything I am leaving out.
