Ladies and Gentlemen:

The following clarification is a follow up to the information that was sent out by Texas Regional Entity (Texas RE) on Monday, May 12, 2008, regarding the Implementation Periods for CIP-002-1 through CIP-009-1.

Texas RE would like to clarify what we understand may be confusion regarding the required implementation of the recently approved CIP standards (CIP-002-1 through CIP-009-1).  I have attached the latest NERC guidance for enforcement of CIP Standards (released yesterday, May 14th).  Please review the information and examples on pages 3 and 4 and in Tables 3 and 4 of this guidance. 

The NERC guidance clarifies that Table 4 was not intended to accelerate the compliance responsibilities of the entities covered by Table 3.   NERC provides an example on page 3, which states:

"A Generator Owner/Generator Operator has a Compliance Registry date of May 31, 2007. Based on table descriptions, the entity would be subject to Table 4 because they have a registration date in 2007. With a registration date of May 31, 2007, the entity would have to be Compliant with CIP 003, Requirement 2 and Substantially Compliant with all other requirements on May 31, 2008. In this example, Table 4 would impose a seven month accelerated schedule to the December 31, 2008 date of Table 3. Therefore, the entity is subject to Table 3, the least restrictive table for their registration.“

I will post the NERC registration dates for all of the ERCOT Region registered entities, by early next week.  I am waiting on some information from NERC before posting this data on our website.