This may be what we need to push the industry over the edge to EISB.  NERC is basically going into a "ignore the market mode" leveraging the threat issue to its fullest.  The fact is, NERC's ability to impact the infrastructure protection is relatively minor.  They mostly deal with communications and data sharing.  The real protection to threats lies in physical security.  We must make clear to the policymakers that NERC and RTOs have little rules and capability to govern physical protection of assets.  These are left in individual asset owners' authority.  Although there is data that can be used negatively, using this data to systematically bring down the grid is not a big bag for the buck that policymakers are concerned about.  Policymakers must not lose perspective that NERC does NOT operate the grid nor is in a position to impose requirements that can protect the infrastructure from physical attack.
(impose a standard to post armed guards at substations?)

 -----Original Message-----
From: 	Nicolay, Christi L.  
Sent:	Wednesday, September 26, 2001 11:57 AM
To:	Yeung, Charles
Cc:	Perrino, Dave
Subject:	FW: NERC question

I agree Dave.  Charles, ideas?

 -----Original Message-----
From: 	Perrino, Dave  
Sent:	Wednesday, September 26, 2001 1:51 PM
To:	Nicolay, Christi L.
Subject:	NERC question

Christi,

Is it too obvious that I have little use for NERC?  

NERC's most recent statements really get me upset, if we don't directly confrom them about this, should we work through EPSA?  NERC's position is counter to everything we have been working so hard to move forward...CA and the rest of the western PTOs are bad enough slowling down development efforts without groups like NERC pontificating publically that FERC should slow things down....

Dave

David F. Perrino
Director, Government Affairs
Enron Corporation
101 California Street, Suite 1950
San Francisco, CA  94111
Phone: 415.782.7801
Fax: 415.782.7854
Mobile: 415.794.8740