direct testimony of the capital expenditures, reliability, and - nyseg

Case 09-E-____; Case 09-G-____ (NYSEG)DIRECT TESTIMONY OF THE CAPITAL EXPENDITURES,RELIABILITY, AND OPERATIONS PANEL12345678910111213141516"electric reliability organization," with FERC oversight in the United States. OnJuly 20, 2006, FERC gave the NERC responsibility for developing and enforcingthese standards as one means of improving the reliability of North America's BPS.On March 15, 2007, FERC approved the first set of 83 mandatory andlegally enforceable reliability standards. Since that time, additional reliabilitystandards have been submitted and approved by FERC. Currently, there areapproximately 100 approved reliability standards, each with multiple subparts.FERC established June 18, 2007 as the effective date of compliance for theapproved mandatory and enforceable reliability standards. Since that date,NYSEG has operated under mandatory, enforceable reliability standards.Q. Do these standards have a material capital or O&M expense impact on theCompany?A. The NERC ERO reliability standards require a significant amount of documentmanagement and compliance monitoring for annual self-certification ofcompliance and periodic NERC audits. Several of the standards also havematerial capital or O&M impacts for implementation. Such standards include:171819202122CIP standards provide a cyber security framework for the physical andelectronic protection of Critical Cyber Assets to support reliable operation ofthe bulk electric system ("BES"). The additional levels of security, beyondindustry standards, result in additional capital and O&M expenses.Facilities Design and Maintenance ("FAC") standards establish criteria forfacility design and maintenance to help avoid adverse impacts on reliability.45