Substations Within 1,500 Feet Now Count in CIP-014-4
FERC has approved a new edition of NERC's physical security standard that requires transmission owners to identify neighbouring substations within 1,500 feet — regardless of who owns them — and include them in fault simulations.
FERC issued an order on 10 September approving NERC Reliability Standard CIP-014-4, and the notice appeared in the Federal Register on 15 September at 91 FR 58430 under docket RD26-9-000. NERC had filed its petition on 16 July, with interventions due a month later.
The change that will take work is a new Requirement R2. Transmission owners must identify proximate existing bulk electric system transmission stations and substations, irrespective of ownership, within 1,500 feet or 457 metres — measured fence line to fence line — and bring them into the assessment. R1 keeps the existing obligation to identify applicable stations at least once every 36 calendar months, including stations planned to be in service within that window.
The simulation requirements in R3 are more prescriptive than before. Steady-state and dynamic simulations each have to be run with at least one system peak load case and one off-peak case. Part 3.3.1.1 requires simulating prior loss of communication and protection systems at the applicable station. Part 3.3.1.3 requires delayed remote clearing times at that station unless technically substantiated otherwise, while 3.3.2.2 requires normal clearing times at the proximate stations. Part 3.3.3 requires documented justification naming the type of credible high-severity physical attack considered and the fault type chosen.
Violation Risk Factors are High for R1, R3 and R5, Medium for R2 and R4. The existing exemption survives for facilities inside a protected area as defined in 10 CFR 73.2 under an NRC-accepted security plan, and for facilities under a Canadian Nuclear Safety Commission plan. The standard runs to twenty pages including the Attachment 1 applicability criteria.
CIP-014-4 takes effect on 1 October 2028, with CIP-014-3 retiring immediately before. The two-year runway is not generous for utilities in dense substation corridors, where R2 turns a single-owner exercise into a data exchange with neighbours who may also be competitors.