MORNING, EVERYBODY. WELCOME TO THE COMMISSION'S ANNUAL RELIABILITY TECH CONFERENCE. THIS IS ONE OF THE MOST IMPORTANT TECHNICAL CONFERENCES WE HOLD EACH YEAR AND I THANK EACH OF OUR PANELISTS FOR COMING HERE TO BE WITH US TODAY. SAFE GUARDING THE RELIABILITY AND SECURITY OF THE NATION'S BULK POWER SYSTEM IS ONE OF THE MOST IMPORTANT RESPONSIBILITIES THAT WE HAVE HERE AT THE COMMISSION IT IS ONE THAT WE SHARE WITH NERC AND THE REGIONAL ENTITIES. SINCE THE PASSAGE OF EP A CT ZERO FIVE THE INDUSTRY MADE STRIDES TOWARD A MORE RELIABLE AND SECURE GRID WHICH COULD NOT HAVE BEEN ACCOMPLISHED FROM A COON CERTED EFFORT WITHOUT THE COMMISSION, NERC AND REGIONALLENT EPI-BLASTIES AND EVERYONE IN INDUSTRY. WE HAVE ACCOMPLISHED MUCH OVER THE PAST 14 YEARS WE CAN'T REST ON OUR LAURELS, BUILDING ON ALL WE'VE ACCOMPLISHED REQUIRES MAINTAINING OPEN, HONEST LINES OF COMMUNICATION, AND RELENTLESS FOCUS ON CONTINUAL IMPROVEMENT. THIS ANNUAL TECHNICAL CONFERENCE IS AN IMPORTANT FORUM FOR ADDRESSING BOTH OF THOSE OBJECTIVES. CURINGTODAY'S TECHNICAL CONFERENCE, WE WILL FOCUS ON FOUR FUNDAMENTAL TOPICS, THE FIRST THE STATUS OF ELECTRICAL RELIABILITY ORGANIZATION AND OVERALL ASSESSMENT OF THE CURRENT STATE OF RELIABILITY. SECOND THE IMPACT OF CLOUD BASED SERVICES AND VIRTUALIZATION AS MORE AND MORE UTILITIES ADOPT THIS TECHNOLOGY. THIRD, RELIABILITY COORDINATOR SEAMS ISSUES AND FOURTH, THE IMPACT OF CHANGES IN COMMUNICATION AND THE POTENTIAL IMPACTS ON THE B. E. S. I LOOK FORWARD TO HEARING THE VIEWS OF OUR PANELISTS ON EACH OF THESE IMPORTANT TOPICS. BEFORE WE GET STARTED, I WOULD LIKE TO MENTION A FEW HOUSEKEEPING MATTERS. NO FOOD OR DRINK ALLOWED IN THE COMMISSION MEETING ROOM, ONLY BOTTLED WATER. PLEASE TURN OFF YOUR CELL PHONES. THE WIFI ACCESS, SEE THE TABLE OUTSIDE THE MEETING ROOM FOR THE GUEST WIRELESS NETWORK RULES AND BEHAVIOR WHICH INCLUDES THE INSTRUCTIONS FOR SIGNING INTO THE WIFI. WE WILL BREAK FOR LUNCH AT 12:30. WE WILL AREY SOUP AT 1:30 WITH THE RELIABILITY COORDINATE SEAMS PANEL. HEARING ROOM TWO IS AVAILABLE FOR STORES BAGS AND FOR OVERFLOW. I WILL BE STEPPING OUT DURING THE SECOND PANEL AND RETURNING FOR THE LAST PANEL ON COMMUNICATIONS. IN MY ABSENCE COMMISSIONENER MC NAMEE HAS GRACIOUSLY AGREED TO CHAIR THOSE PANELS. FINALLY WE WOULD LIKE TO LIMIT INDIVIDUAL STATEMENTS TO NO MORE THAN FOUR MINUTES, DUE TO TIME CONSTRAINTS. WHILE IT'S NOT A HARD STOP IN THE INTEREST OF HEARING FROM ALL THE PANELISTS AND ALLOWING FOR THE DISCUSSION I WOULD ASK THAT YOU HIGHLIGHT THE MAJOR POINTS FOR YOUR STATEMENTS RATHER THAN READING STATEMENTS. AND THEN NOW FOR THE SECURITY STATEMENT, MEMBERS OF THE PUBLIC ARE INVITED TO OBSERVE WHICH INCLUDES ATTENDING, LISTENING AND TAKING NOTES, BUT DOES NOT INCLUDE PARTICIPATING IN THE CONFERENCE OR ADDRESSING THE COMMISSION. ACTIONS THAT PURPOSELY INTERFERE OR ATTEMPT TO INTERFERE WITH THE COMMENCEMENT OR CONDUCTING OF THE CONFERENCE OR INHIBIT THE AUDIENCE'S ABILITY TO LISTEN OR OBSERVE OR LISTEN TO DISCUSSIONS INCLUDING ATTEMPTS BY AUDIENCE MEMBERS TO ADDRESS THE COMMISSION WHILE THE MEETING IS IN PROGRESS ARE NOT PERMITTED. ANY PERSONS ENGAGING IN SUCH BEHAVIOR WILL BE ASKED TO LEAVE THE BUILDING, ANYONE WOREFUSES TO LEAVE VOLUNTARILY WILL BE ESCORTED FROM THE BUILDING AND FINALLY WE WILL NOT HAVE A GENERAL Q&A WITH THE AUDIENCE DURING THE CONFERENCE BUT WE WILL ACCEPT WRITTEN COMMENTS IN DOCKET 80-13-18, FOR FORMAL COMMENTS AND DEADLINES WILL BE ISSUED IN THE NEAR FUTURE. WITH THAT I WILL TURN TO MY COLLEAGUES FOR ANY OPENING STATEMENTS.

THANK YOU MR. CHAIRMAN. I'D ALSO LIKE TO WELCOME EVERYONE TO TODAY'S CONFERENCE. I KNOW A LOT OF PEOPLE HAVE FLOWN TO BE HERE AND I PARTICULARLY WANT TO THANK ALL OF THE PANELISTS AT ALL FOUR OF THE PANELS. THIS IS THE DAY THAT I LOOK FORWARD TO EVERY DAY, EVERY YEAR. IT'S A VERY IMPORTANT CONFERENCE AND ONE THAT I REAL LE ENJOY, I AM PARTICULARLY EXCITED ABOUT THE FIRST PANEL WHERE WE TAKE A BROAD LOOK AT THE STATE OF RELIABILITY AND THE WORK OF THE ERO INCLUDING THE RES AND ALL OF OUR COLLECTIVE WORKS AND WHAT WE SHOULD BE DOING MORE OF. I HAVE PILES OF QUESTIONS PREPARED BUT I WILLED ADD WHAT I AM SURE WILL BE THE MOST VALUE I WILL ADD ALL DAY WHICH IS TO SAY I HAVE HAD A LOT OF MEETINGS ON THIS ROOM AND ON A DAY LIKE TODAY, IT GETS REALLY, REALLY HOT, I WILL TAKE OFF MY JACKET IF IT GETS HOT AND I STRONGLY INVITE THOSE TO DO SO, IT WILL BE 90 SOMETHING DEGREES OUT THERE AND I'M SURE BY THE THIRD PANEL, WE'LL BE FEELING IT.

THANK YOU MR. CHAIRMAN, I WOULD LIKE TO THANK EVERYONE IN PUTTING TOGETHER THIS CONFERENCE, THEY DID A LOT OF WORK AND A LOT OF BRIEFINGS AND I APPRECIATE EVERYBODY'S EFFORTS AND I WANT TO THANK THE PANELISTS FOR TRAVELING ACROSS THE COUNTRY TO BE HERE TODAY. AS EVERYBODY KNOWS IT'S AN EXCITING TIME TO BE IN THE ENERGY INDUSTRY AND THESE CHANGES DO PRESENT CHALLENGES BUT THAT DOESN'T MEAN WE NECESSARILY NEED TO RETURN TO THE GRID OF YESTERDAY AND INSTEAD WE NEED TO FIGURE OUT WAYS TO ADDRESS THE NEED SO CAN YOU REACH THE GRID OF THE FUTURE. TODAY'S TECHNICAL CONFERENCE FOCUSES ON SOME OF THE MOST INTERESTING CHANGES TO OUR SYSTEM, FROM LEVERAGES TECHNOLOGIES AND CLOUD SERVICES AND VIRTUALIZATION AND ELECTRIC COMPANIES INCREASING THE NEEDS FOR SPECTRUM AND THOSE ACROSS THE SEAMS TODAY, I LOOK FORWARD TO HEARING FROM EVERYONE TODAY AND WE WILL HAVE A GOOD DISCUSSION. THANK YOU.

I ALSO WANT TO THANK THE PANELISTS AND THE FERC STAFF FOR THE WORK ON THIS AND THIS IS MY FIRST CONFERENCE FOR THE RELIABILITY AND IT'S ONE I'VE BEEN LOOKING FORWARD TO BECAUSE IT'S SO VITALLY IMPORTANT ESPECIALLY WITH THE TRANSFORMATION OF THE GRID AND CONVERGENCE OF NEW TECHNOLOGIES, BE COMMUNICATIONS TECHNOLOGY AND OF COURSE THE VARIOUS THREAT. USED TO BE WE JUST WORRIED ABOUT THE WEATHER FOR RELIABILITY, NOW WE'RE WORRIED ABOUT MANMADE ACTORS IN THE PHYSICAL AND CYBER LEVEL. SO I'M LOOKING FORWARD TO HEARING ABOUT THE VARIOUS ISSUES WE WILL COME AS WE GO TO VIRTUALIZATION, CLOUD BASED SERVICES, USE OF SPECTRUM AND HOW DIFFERENT AGENCIES AND THE FEDERAL GOVERNMENT ARE LOOKING AT IT AND HOW UTILITIES USE IT AND I THINK THAT IT'S EASY WHEN WE'RE HERE IN THIS JOB, FOCUS ON THE DAY-TO-DAY WORK, LOOKING AT TARIFFS, LOOKING AT RATES, BUT ONE OF THE MOST IMPORTANT THINGS WE DO IS DEALING WITH RELIABILITY AND I THINK EACH OF YOU FOR BEING HERE AND FOR TAKING THE TIME FOR EVERYBODY AT FERC AND NERC FOR TAKING THE TIME. WE NEED TO AT A FOCUSED ON THIS AND THIS IS SOMETHING VERY IMPORTANT. THANK YOU.

THANK YOU. THAT WILL TURN IT OVER TO OUR PANEL. STARTING WITH JIM ROTH.

THANK YOU MR. CHAIRMAN, I WANT TO THANK THE COMMISSION FOR THE OPPORTUNITY TO BE HERE THIS MORNING, AS WE ALL KNOW ELECTRICITY IS AN ESSENTIAL COMOPPOSITE BEHAVIORIAL PHENOTYPENT OF MODERN SOCIETY AND BY CONDUCTING THE CONFERENCE YOU UNDERSCORE THE IMPORTANCE OF ISY CURITY OF THE POWER SYSTEM AND OUR RESPECTIVE RESPONSIBILITY TO THE CITIZEN OF THE UNITED STATES AND NEARLY 400 MILLION PEOPLE ACROSS NORTH AMERICA THAT RELY ON ELECTRICITY FOR THEIR EVERYDAY LIVES, ALTHOUGH WE DON'T HAVE OUR HANDS ON ANY CONTROLS, THE WORK OF FERC AND STRENGTHEN THE FABRIC OF THE INDUSTRY, I THINK WE CAN ALL TAKE PRIDE IN RECOGNIZING THAT THE RELIABILITY AND THE GRID IS STRONG AND CONTINUES TO IMPROVE, AS OUR RECENT STATE OF RELIABILITY REPORTED 2018 WAS ONE OF THE BEST PERFORMING YEARS WE'VE HAD IN RECENT MEMORY AND THIS ALL THE MORE REMARKABLE WHEN YOU CONSIDER THE TRANSFORMATIONAL CHANGE GOING ON IN TECHNOLOGY, FUEL MIX, THE DEPLOYMENT OF MORE DIGITIZED AND DISTRIBUTED RESOURCES AND THE PERSISTENT SECURITY THREATS FROM DETERMINED ADVERSARIES BUT WITH CONTINUED DILIGENCE AND VIGILANCE I'M QUITE CONFIDENT THAT THE ELECTRICITY SECTOR WILL NAVIGATE THE CHALLENGES IN FRONT OF IT. LAST YEAR WHEN I WAS HERE I IDENTIFIED THREE PRIORITIES WE WERE FOCUSED ON WITHIN THE ERO ENTERPRISE. FIRST MONTH THEM ARE THE ISSUES OF SECURITY OF THE SYSTEM. LAST YEAR WE SORTED OUT THE LEADERSHIP OF THE EI SACK AND THE TEAM THERE IS FOCUSED ON EXECUTION OF THE FIVE YEAR TRANSLATIONAL RESEARCH TAOEPBLGIC PLAN THAT WAS PUT IN PLACE. EARLY RETURNS FROM THAT WORK ARE GOOD AS WE EXPANDED OUR WATCH CAPABILITY AND OUR ANALYTICAL CAPABILITIES AND CONTINUE TO DEVELOP NEW TOOLS FOR COMMUNICATING INFORMATION TO INDUSTRY SUCH AS OUR RECENTLY ESTABLISHED ALM POINTS BULLETINS. SUPPLY CHAIN REMAINS A SIGNIFICANT AND CHALLENGING ISSUE AS WE ALL KNOW. WE ARE PREPARING TO ISSUE A 1600 DATA REQUEST, TO BETTER INFORM OUR THINKING ON THE NEXT STEPS TO IMPROVE THE EFFECTIVENESS OF SUPPLY CHAIN AND THE SIP STANDARDS IN GENERAL AS WELL AS NERC ALERT TO GATHER MORE SPECIFIC DATAOT EXTENDED USE OF CERTAIN CHINESE MANUFACTURED EQUIPMENTOT BULK POWER SYSTEM. NONAPOPTOTIC YOU THAT [INDISCERNIBLE] FINISHED TECH IN IICAL WORK ON EMT, WE HAVE WORKED WITH EXPERTS TO DETERMINE THE RIGHT REGULATORY APPROACH FROM FACILITIES FROM AN EMP EVENT AND WE'RE EXPLORING OPPORTUNITIES TO ALLOW FOR PRUDENT AND USE OF SECURE AND FOCUSING ON SECURE INFORMATION AND DATA AS OPPOSE TO THE SECURITY ITSELF. THE SECONDARY OF KEY FOCUS FOR ITSELF ARE THE TRANSITIONS OCCURRING IN THE WESTERN CONNECTION, NERC AND WEC ARE FOCUSED ON THE CERTIFICATION OF THE RCS AND INSURING THAT THE INFORMATION SHARING AND COORDINATION ARE IN PLACE TO INSURE SEAMLESS OPERATION AMONG THEM. THIRD AREA ARE ISSUES SURROUNDING THE RAPIDLY CHANGING RESOURCE MIX IN THE INDUSTRY. AS WE REPORTED LAST YEAR THE PASS INTENDED OF THAT TRANSITION IS CRITICAL AND NEEDS TO BE MANAGED TO INSURE ONGOING FUEL AND RESOURCE ADEQUACY TO SERVE LOAD WHILE ADDRESSING A COUPLE RELIABILITY CHALLENGES AS WE MOVE FROM A SOLID LIQUID FUEL BASED INDUSTRY TO ONE THAT'S MUCH MORE STOIKASTIC MODELASTIC IN NATURE. THE FIRST IS HOW TO IMPOSSIBLE TO BUILD GREAT RESOURCES, WE ISSUED A RELIABILITY GUIDE LINE ON INVERTERS AND ARE WORKING ON IMMEDIATEIFICATION TO OUR PRC STANDARDS TO ADDRESS THE ISSUES WE LEARNED AND UNCOVERED FROM THE USE OF THESE RESOURCES EMPLOY LAST YEAR I PLEDGED WE WOULD PIVOT FROM INCREASING USE IN THE NATURAL GAS IN THE SYSTEM TO FOCUSING ON DEVELOPING SOLUTIONS AND RESOLVING MANY OF THE PLANNING OPERATING AND INCREASING SECURITY ISSUES RELATED TO THE INTERDEPENDENCE OF THE TWO INDUSTRIES, MARK WILL DISCUSS IN MORE DETAIL THAT OUR ELECTRIC GAS WORKING GROUP WHICH WE CHARTERED TO ADDRESS THESE ISSUES IN A FEW MACHINEUTES. IN TERMS OF LEADING NER C AND THE EO ENTERPRISE WE HAVE TWO MAJOR PRIORITIES, THE FIRST IS KPAPTUREING EFFECTIVENESS AND EFFICIENCY OPPORTUNITIES WITH THE NEAR FOCUS ON THE BIG THREE. THE FIRST OF THAT IS THE STANDARDS OF EFFICIENCY REVIEW WHERE THE COMMISSION'S APPROVAL OF THE RETIREMENT, WE HAVE PROPOSED COMING OUT OF PHASE ONE, AND ARE CURRENTLY WORKING NOW ON PHASE TWO OPPORTUNITIES TO INCLUDE A REVIEW OF THE SIP STANDARDS. SECOND IS COMPLETING THE DEVELOPMENT AND DEPLOYMENT OF THE WORK MANAGEMENT TOOL ACROSS THE ENTERPRISE, THIS WILL IMPROVE SECURITY OF OUR ACTIVITIES AND ENABLE BETTER REPORTING AND PERFORMANCE MANAGEMENT OF OUR CME PROCESSES AND INSURE HIGHER LEVEL OF EXECUTIONAL CONSISTENCY ACROSS THE REGIONAL ENTITIES. AND THE THIRD AREA IS REIMAGINING OUR STAKEHOLDER ENGAGEMENT STRUCTURE. TO BETTER ALIGN OUR COMMITTEES WITH THE EMERGING REALITIES OF THE INDUSTRY, MORE INTEGRATION ACROSS PREVIOUSLY SILOED DISCIPLINES AND BRING MORE FOCUS ON DELIVERABLES THROUGH MISSION DRIB TASK FORCES. LASTLY I WOULD BE AMISS IF I DIDN'T COMMENT ON WHAT WE WERE FOCUSED ON CAPTURING A ONCE IN RAY LIFETIME OPPORTUNITY TO RENEW WE COME TOGETHER TO EXECUTE OUR SHARED MISSION. OVER THE LAST 18 MONTHS THE ENTERPRISE HAS UNDERGONE SIGNIFICANT STRUCTURAL AND SOCIAL CHANGE AND THESE HAVE UNLOCKED OUR IMAGINATIONS AS THOU WE CAN WORK TOGETHER TO EMBRACE THE BILLIANCE OF THE REGIONAL MODEL AND MAKE IT WORK AS A SINGLE SYNCHRONOUS MACHINE. I LOOK FORWARD TO DISCUSSING THESE AND OTHER ISSUES WITH YOU TODAY, SO THANK YOU VERY MUCH FOR THE OPPORTUNITY.

THANK YOU ALSO FOR THE OPPORTUNITY TO PARTICIPATE IN TODAYAD PANEL. THIS HAS BECOME THE PREMIER VENUE TO DISUS THE RELIABILITY AND PEER ON THE TO HORIZON FOR E MERGING RELIABILITY RISK AND MITIGATION TO THOSE RISKS. I'LL FOCUS MY REMARKS TO TWO AREAS, FIRST DEFINEDDINGS OF OUR REPORT AND THE STATUS OF TWO PRIORITIES, ELECTROMAGNETIC PULSE AND NATURAL GAS DELIVERY. LAST WEEK WE PUBLISHED ANNUAL STATE REPORT WHICH IDENTIFIES RELIABILITY AND ACTION TRENDS AND ACTIONS TO ADDRESS RISKS AND WHETHER MITIGATIONS ARE WORKING OR IF THERE ARE OTHER INTERVENTIONS THAT ARE NECESSARY. OUR GELLERT WITH THIS REPORT IS TO INFORM REGULATORS, POLICY MAKERS AND INDUSTRY LEADERS. BASED ON THE METRICS THAT THE ERO ENTERPRISE TRACKS, ON AVERAGE 2018 WAS A GOOD YEAR FOR RELIABILITY AND NORTH AMERICA'S BULK POWER SYSTEM REMAINS HIGHLY RELIABILITY. EXTREME WEATHER CONTINUES TO BE A LEADING CONTRIBUTOR TO GLOBE LOSS, ALTHOUGH IT WAS LOWER THAN PRIOR FOUR YEARS. NO SIGNIFICANT NONWEATHER RELATED EVENT UPONS, IN ADDITION, NOT INCLUDING INCONSEQUENTIAL LOAD LOSS OR DISTRIBUTION ANALYSIS, 99.92% OF THE TIME THERE WERE NO OPERATOR CONTROLLED FIRM FLOW CHECK. FREQUENCY RESPONSE IMPROVED FOR ALL INTERCONNECTIONS, WHILE PROTECTION IN THIS SYSTEM TICKED SLIGHTLY HIGHER IN 2018, WE ARE SEEING A STATISTICALLY SIGNIFICANT DOWNWARD TREND OVER A FIVE YEAR PERIOD. TO ADDRESS INVERTER BASE RESOURCE PLAN AND UNPLANNED WIDE SPREAD LOSS DURING LINE OUTAGES WE REMAIN FOCUS ON IMPLEMENTING GUIDELINES, RELIABILITY STANDARDS AND INCREASE ENGAGEMENT ON DEVICE PERFORMANCE. THE ERO ENTERPRISE CONTINUES TO MONITOR GAS FIRE POWER PLANTS DURING COLD WEATHER AND PAID CLOSE ATTENTION TO THE PERFORMANCE DURING THE POLEAR VORTEX. ALTHOUGH THERE HAVE BEEN SIGNIFICANT IMPROVEMENT, ISSUES PERSIST IN CERTAIN AREAS. TEXAS IS ANOTHER FOCUS AREA AS IT'S PROECTOMYOSIN SKWREBGTED RESERVE MARGINS IN TWEBT 19 WE REMAIN CONCERNED ABOUT THE ADEQUACY OF THE SUMMER AND THAT ERC HAS NAVIGATED LOWER MARGINS IN PREVIOUS SUMMERS. IN 2018 DESPITE CONTINUED THREATS THERE WERE NO REPORTED CYBER OR PHYSICAL ATTACK INDENSES IN UNAUTHORIZED THAT RESULTED IN UNAFFILIATED AUTHORIZED CONTROL, ACTION OR LOSS OF LOAD. AT THE SAME TIME WE ARE MINDFUL OF THE NEED TO CONTINUE OUR VIGILANCE AND WE THANK THE COMMISSION FOR APPROVING NERCPETRESSABLE CISION REGARDING ENHANCED CYBER REPORTING, BASED ON THESE FINDINGS NERC IS BEDDING AND MODELING FOR THE BULK POWER SYSTEM OR TRANSFORMATION, I CALL IT METAMORPHOSIS FOR A PARTICULAR FOCUS ON FREQUENCY RESPONSE AND INVERTER BASE RESOURCE ISSUES AND RESOURCE ADEQUACY ENCLUEDING CAPACITY AND ENERGY. ERO AND INDUSTRY SHOULD DEVELOP MEASUREMENT AND METRICS FOR RESILIENCE AND THERE SHOULD BE CLOSE CONTINUED COLLABORATION ON PHYSICAL AND CYBERSECURITY. ON THE ELECTROMAGNETIC PULSE OR EMP, OR SECOND PHASE RESEARCH WE HAVE LAUNCH AID TASK FORCE TO IDENTIFY KEY AREAS OF CONCERN AND POTENTIAL AREAS IF ARE IMPROVEMENT. THE TASK FORCE RESUBIT BEST PRACTICES, GUIDELINES AND DEVELOP IF NEEDED ANY STANDARD AUTHORIZATION REQUEST, THAT'S TARGETED FOR NEAR THE END OF THE YEAR. REGARD TO NATURAL GAS, NERC'S GAS COMMITTEE INFORMED THE GAS WORKING GROUP WHICH WORKED ON GUIDELINE ON FUEL ASSURANCE, THIS WILL ADDRESS NATURAL GAS PIPELINE CONTINGENCY RISK AND SET THE STAGE FOR ACTION THAT MIGHT INCLUDE ENHANCING EXISTING OR CREATING NEW RELIABILITY STANDARDS, THE WORKING GROUP EXPECT ITS TO BE READY BY YEAR END. SO I THANK THE COMMISSION FOR HAVING US HERE TODAY AND I LOOK FORWARD TO ADDITIONAL CONVERSATION ON THESE ISSUES.

THANK YOU FOR INVITING ME, COMMISSIONER LAFLEUR, I'M GOING TO MISS WORKING WITH YOU, AND I WANT TO THANK YOU FOR YOUR TENURE RELIABILITY, YOU'VE BEEN FANTASTIC.

THANK YOU TIM.

I AM HERE AS REGION AMILLIO ENTITY FOR ISSUES YOU PROVIDED IN THE AGENDA, THE REGIONS SHARE THE ERO RISK PRIORITIES THAT WERE IDENTIFIED IN THE RELIABILITY REPORT AND I WILL HIGHLIGHT SOME OF THOSE IN A FEW MOMENTS BUT FIRST I DO WANT TO NOTE HOWEVER, THAT RELIABILITY AND SECURITY RISKS CAN VARY ACROSS THE REGIONS DUE TO THE REGIONS UNIQUE GEOGRAPHICAL LOCATIONS, ELECTRIC AT SYSTEM CONFIGURURATIONS AND LOAD DENSITY. TO ACCOUNT FOR THESE VARIATIONS, THE REGIONS DO CONDUCT SEPARATE REGIONAL RISK ASSESSMENTS TO PRIORITIZE THE ELEMENTS FACING OUR INDIVIDUAL FOOTPRINT AND TO INCLUDE THESE UNIQUE REGIONAL RISKS AND CONSIDERATIONS. THIS IS ONE OF THE REAL CHARGEABLE BENEFITS OF THE TELEIDATED MODEL THAT FORMS THE BASIS OF THE ERO AND DEMONSTRATES THAT THE VALUE OFFING HAVING COMPLEMENTAR SKPE BAKUGAN SUPPLEMENTAL ANALYSIS PERFORMED THAT GIVES US THE ABILITY TO IDENTIFY SPECIFIC RISKS PARTICULARLY TO OUR FOOTPRINTS AND TO WORK CLOSE LOW WITH INDUSTRY IN A LABRATIVE FASHION TO IDENTIFY AVENUES TO ADDRESS THOSE RISKS. REGARDING ERO WIDE RISK FACING INDUSTRY, CYBER AND PHYSICAL SECURITY CONTINUES TO BE A MAJOR FOCUS OF REGIONS AMONG MANY OF THE EPTITYS WE WORK WITH HAVE SUCCESSFUL CYBERSECURITY PROGRAMS AND WE HAVE SEEN SOME OF OUR ENTITIES FACE SIGNATURES 95 CANT CHALLENGES IN THIS AREA GIVEN THE NATURE OF THE THREATS THEY'RE DEALING WITH, SO WE MUST STAY VIGILANT ON CONSTANTLY WORK TO IDENTIFY AND MITIGATE RISKS IN THIS AREA AND WE MUST DO THAT BEFORE THE RISKS ARE REALIZED. I'M PROUD OF THE WORK WE HAVE DONE TO DATE WITH OUR INDUSTRY PARTNERS TO HELP IMPROVE THEIR SIP PROGRAMS AND CULTURES AND WE BRO VIEDED EXTENSIVE OUTREACH EFFORTS TO THEM IN THIS PROCESS INCLUDING THINGS LIKE SUCH AS ASSISTED WORKSHOPS AND REPORTS. ANOTHER KEY ERO WIDE RISK AREA INVOLVES INTERDEPENDENCIES AND COMPLEXITY SURROUNDING GAS AND ELECTRIC COORDINATION, DEPLOYMENT OF NEW TECHNOLOGY AND VIRTUAL MACHINIZATION WHICH YOU WILL HEAR ABOUT LATER ITED AND THE CHANGING NATURE OF OUR POWER SYSTEM BUT I ALWAYS LOOK AT THESE CHANGES AS POSITIVE OPPORTUNITIES FOR US TO IMPACT THIS IN A POSITIVE WAY, WE CAN RESTRUCTURE THINGS, PLAN FOR THESE THINGS AND BUILD IN PROTECTIONS AS WE REDESIGN ON THE POWER SYSTEM CHANGES ON IT SO IT'S NOT ALL DANGEROUS AND BAD WITH THE CHANGE. NERC AND THE REGIONS DO PLAY A ROLE OF ADDRESSING THE RISK AND HIGH FREQUENCY EVENT SUCH AS PIPELINE FAILURES AND EMP. IT'S IMPORTANT THAT WE STUDY THESE RISKS AND THAT WE SHARE OUR KNOWLEDGE ACROSS THE INDUSTRY AND WITH POLICY MAKERS. AS JIM SAID ALTHOUGH WE DON'T HAVE OUR HANDS ON LEVERAGE WE CAN INFLUENCE AND PROVIDE INFORMATION AND DIRECTION. SPECIFICALLY, NERC AND THE REGIONS PROVIDE VALUE BY STUDYING THESE AREAS TO IDENTIFY EMERGING RISKS AND COMMON FAILURE MODES TO IDENTIFY MEASURES AND MITIGATING ACTION FIST ARE THESE AND TO IDENTIFY THE ROOT CAUSES LEARN FROM ACTUAL EVENTS. EFFORTS TO ENHANCE THE RESILIENCE ARE NECESSARY TO HELP W STAND AND HIGH FREQUENCY EVENT WHEN IS THEY DO OCCUR AND NERC AND THE REGIONS FOCUS OUR RESILIENCE IN RECENT YEARS. THE RECENT REGIONALLENTITY CHAIRMANS THAT HELP TO LEVELLIZE THE SIZE AND RISKS AND BREDTH AND DEPTH OF WORK THAT'S DONE ACROSS THE REGIONS AND BETTER POSITIONS THEM TO PERFORM OUR CRITICAL ROLES TO INSURE RELIABILITY AND SECURITY OF THE GRID AND I CAN SAY WITH CONFIDENCE THAT THE REGIONS ALWAYS ENGAGE AND CONTINUOUS IMPROVEMENT AND WE DO PREACH THIS TO THE INDUSTRY AND WE PRACTICE IT OURSELVES. SO WE'RE ALWAYS SEEKING TO FURTHER ENHANCE OUR EFFICIENCY, OUR EFFECTIVENESS AND CONSISTENCY, ONE KEY EFFORT THERE IS THE ALYME TOOL THAT JIM MENTION THAD WILL BE A COMMON COMPLIANCE MONITORING SYSTEM FOR ALL ENTITIES ACROSS AMERICA, THE REGIONAL BOOTS ON THE GROUND ENHANCES RELIABILITY AND IMPORTANCE IN NUMEROUS WAYS AND I SPOKE EARLIER THAT RISKS AND VARY ACROSS THE REGION ACROSS THE GERONTOLOGYSTS ON GRAPHIC AND ELECTRICAL CONFIGURURATION AND THE REALITY OF EACH REGIONAL IF THE PRINT. AS SUCH THE REGIONS DO SERVE AS THE EXPERTS FACING THEIR PARTICULAR AREAS OF THE COUNTRY, MORE OVER THE REGIONS HAVE OVER A DECADE NOW OF FIRST HAND EXPERIENCE FROM THOUSANDS OF ENGAGEMENTS WITH ENTITIES ON HOW TO BEST MITIGATE THESE RISKS AND DRIVE CONTINUOUS IMPROVE. THIS INCLUDES IMPORTANT ACTIVITIES THAT OCCURS OUTSIDE OUR PRACTICE DITIONAL TOOLS SUCH AS STANDARDS AND ENFORCEMENT AND AUDITING. AS WE ALL KNOW THREATS TO THE GRID ARE EVOLVING AND WE MUST WORK TO STAY AHEAD OF THESE THREATS TO INSURE RELIABILITY AND SECURITY. THE REGIONS LIVE ON THE FRONT LINE OF ISY COOURITY AND WE'RE POSITION AND EQUIPMENTED TO IDENTIFY THESE IPT GREATER CLUING EVENTS ANALYSIS, ENFORCEMENT, RELIABILITY ASSESSMENT AND DATA ANALYTICS ONCE WE IDENTIFY A THREAT WE NEED TO PRIORITY WHICH OF OUR TOOLS WE WILL USE TO ADDRESS IT. STANDARDS ESSENTIAL TO OUR RELIABILITY MISSION AND ARE APPROPRIATE FOR ADDRESSING WIDE SPREAD WELL UNDERSTOOD RISK THAT INSURING UNIFORM PERFORMANCE IS KEY TO ADDRESSING. SO THIS CONCLUDES MY REMARKS AND I THANK YOU FOR INVITING ME AND I LOOK FORWARD TO YOUR QUESTIONS; GOOD MORNING I'M GENNENER STERLING VICE PRESIDENT OF NERC COMPLIANCE AND SECURITY FOR AXALON, ABOUT BEHALF OF EEI AND E, I'S MEMBERS, THANK YOU FOR THE OPPORTUNITY TO PER TAIS INHIBITOR IN THE TODAY'S TECHNICAL CONFERENCE AND IMPORTANT FORM TO DISCUSS THE ERO AND THE BULK RAOEUBLT OF THE ELECTRIC AT SYSTEM. AS I'M SURE YOU ARE AWARE AXALON COMPANIES REPRESENTS EVERY STAGE OF THE ENERGY VALUE CHAIN THROUGH OUR SIX UTILITIES, GENERATORS AND OUR RETAIL ELECTRIC SERVICE PROVIDER. TODAY I WILL FOCUS ON THE PACE OF CHANGE TO THE GRID, THE NEED FOR COORDINATION AND THE INFORMATION SHARING AND PROTECTION TO SUPPORT GRID RELIABILITY. THE GREATEST CHALLENGE THE ELECTRIC INDUSTRY FACES TODAY FOR MAINTAINING RELIABILITY IS THE RAPID CHASE'RE PACE OF CHANGE TO THE GRID FOR POLICY PREFERENCES, NEW TECHNOLOGIES THAT SEEK TO PROVIDE CLEANER MORE EFFICIENT ELECTRICITY TO CAN UTV MERS. HOWEVER THE THREAT SUCH AS MALICIOUS ACTORS SEEKING TOAC CESS CONTROL AND POTENTIAL LE DISRUPT THE GRID ARE ALSO INKEYS CREASING. MEAN WHILE THE GRID IS BECOMING MORE DEPENDENT ON OTHER SECTORS INCLUDING BUT NOT LIMITED TO MANUFACTURES AND SERVICE PROVIDERS OF CYBER SYSTEM SYSTEM, COMMUNICATIONS AND FUEL SUPPLIES SUCH AS NATURAL GAS. THE SIX STANDARD VS ESTABLISHED A COMPREHENSIVE SET OF REQUIREMENTS TO SUPPORT RELIABILITY OF BULK POWER SYSTEM. HOWEVER, THE PACE OF CHANGE TO THE MANDATORY STANDARDS HAS BEEN AND CONTINUES TO BE SUBSTANTIAL SINCE THEY ORIGINALLY BECAME ENFORCEABLE NEARLY TEN YEARS AGO. MEAN WHILE SOME OF THE THE SIP REQUIREMENTS MAY NOT BE ENOUGH TO KEEP UP WITH NEW AND EVOLVING TECHNOLOGIES SUCH AS CLOUD SERVICES AND VIRTUALIZATION WHICH WILL BE DISCUSS INDEED GREATER DETAIL IN ANOTHER PANEL. IS EEI SEEKS APPROACHES TO ADDRESS THESE CHANGES AS THE IN, ERC RELIABILITY STANDARDS ALONE MAY NOT BE SUFFICIENT TO ADDRESS EMERGING RISKS TO RELIABILITY IN A TIMELY MANNER. FOR NEW RISKS, RESEARCH AND ANALYSIS WILL BE NEEDED TO IDENTIFY APPROPRIATE TECHNICAL SOLUTIONS FOR EXAMPLE, AT THE END OF APRIL, AFTER THEY RELEASED THEIR LATEST REPORT ON THE IMPACT OF EMP. NERC ESTABLISHED A EMP TASK FORCE TO IDENTIFY AND ADDRESS EMP RAOEUBLT CONCERNS WHILE THE TASK FORCE HAS AN AGGRESSIVE SCHEDULE, THE OUTLINE IS METHODICAL AND STRUCTURE FOR ADEQUATE ANALYSIS FOR MANAGING THE RISK, THE IN ADDITION TO RISKS TPRU NEW TECHNOLOGY, THE COMMISSION IS RIGHTLY FOCUSING MORE ON RISK INTRODUCED BY OTHER SECTORS. WE ENCOURAGE THE COMMISSION TO COORDINATE WITH OTHER INDUSTRIES SUCH AS NATURAL GAS AND COMMUNICATIONS PROVIDERS AND THEIR RESPECTIVE REGULATORS AND TO WORK CLOSELY WITH THOSE FEDERAL AGENCIES RESPONSIBLE FOR NATIONAL SECURITY TO ADDRESS THESE CROSS SECTOR RISKS. THE COMMISSION'S COLLABORATION WITH D. O. E. FOR THE MARCH TECHNICAL CONFERENCE ON SECURITY INVESTMENTS WAS A GOOD START TO INSURE GRID RELIABILITY. THE INDUSTRY CONTINUES TO INVEST SIGNIFICANT RESOURCES IN THE EI FACT PROVIDED BY NERC TO PROVIDE VOLUNTARY INFORMATION FOR INFORMATION. INDUSTRY EXECUTIVES ARE WORKING WITH THE ISAC ON A MULTIYEAR PLAN TO EXPAND AND STRENGTHEN THE VALUE OF THE EI SAC, WE ENCOURAGE THE COMMISSION TO CONTINUE THIS EFFORT. THIS WILL REQUIRE ROBUST INFORMATION SHARING AND COLLABORATION BETWEEN INDUSTRY, NERC AND THE FEDERAL GOVERNMENT TO IDENTIFY RISK AND WILL REQUIRE EACH OF THESE ENTITIES TO PROTECT SENSITIVE INFORMATION N. CONCLUSION, I APPRECIATE THE OPPORTUNITY TO PARTICIPATE IN THIS TECHNICAL CONFERENCE AS IT PROVIDES THE NEEDED FORUM TO DISCUSS THE IMPORTANT ISSUES ASSOCIATE WIDE RELIABILITY. WE LOOK FORWARD TO COLLABORATING WITH THE COMMISSION, INY INY AND STAKEHOLDERS IN CONSIDERING SOLUTIONS THAT SUPPORT OUR COLLECTIVE EFFORTS TO INSURE CONTINUED RELIABILITY OF THE BULK ELECTRIC SYSTEM. THANK YOU.

GOOD MORNING AND THANK YOU FOR THE OPPORTUNITY FOR PUBLIC ABILITY TO PARTICIPATE IN THE COCK FECAL CONFERENCE. AS THE AGENDA FOR THIS YEAR CONFERENCE SHOWS, THE ELECTRIC STAKEHOLDERS INCLUDING THE COMMISSION CONTINUE TO FACE IMPORTANT QUESTIONS ABOUT HOW TO BEST PROTECT AND MAINTAIN RELIABILITY OF THE BULK ELECTRIC SYSTEM IN AN EVOLVING LANDSCAPE OR TECHNOLOGICAL CHANGES CAN PRESENT BOTH RISK AND OPPORTUNITIES. NERC AND THE REGIONAL ENTITIES PLAY A CENTRAL ROLE IN MAINTAINING THE EES RELIABILITY AND I COMMEND THE COMMISSION FOR CONVENING THIS PANEL TO EXPLORE OW NERC AND THE REGIONAL ENTITIES IN COORDINATION WITH INDUSTRY STAKEHOLDER CANS BEST ACCOMPLISH THIS COMMON MISSION. I APPRECIATE THE CHANCE TO SHARE THE PERSPECTIVE THE AMERICAN PUBLIC POWER ASSOCIATION ON THE SELECT PANEL ISSUES. AS THE COMMISSION KNOWS THERE ARE 2000 PUBLIC POWER UTILES BIG AND SMALL THROUGHOUT THE NATION AND WHILE 12% OF THAT NUMBER ARE NERC REGISTERED ENTITIES ALL EACTUALITYS SHARE AN INTEREST IN PROVIDING ISY COOURE, LOW COST RELIABILITY ELECTRIC SERVICE. I LOOK FORWARD TO DISCUSS ALL THE ISSUES THE COMMISSION IDENTIFIED IN THE NOTICE, BUT IN MY INTRODUCTORY REMARKS I WOULD LIKE TO FOCUS ON TWO THINGS. FIRST AS AN OVERARCHING PRIORITY, THE COMMISSION, NERC AND INDUSTRY COLLABORATIVE RELIABILITY REGIME SHOULD CONTINUE TO MAINTAIN A FOCUS ON OPERATIONAL EFFICIENCY AND EFFECTIVENESS. IN 2018, NERC INITIATED A PROCESS, TO ADENTIFY AND EVALUATE OPPORTUNITIES TO IMPROVE THE ERO ENTERPRISE. EFFECTIVENESS AND EFFICIENCY INCLUDING EFFECTIVENESS AND EFFICIENCY OF NERC STAKEHOLDER OPERATIONS OF THE ERO ENTERPRISE. AA PPA, ENCOURAGE THAD NERC CONTINUES TO ENGAGE IN THIS EFFORT. THIS IS NOT TO SUGGEST THAT NERC SHOULD CONS FREIGHT ON COST SAVINGS OR CUTTING BACK, BUT GREATER EFFICIENCY SHOULD NOT COME AT THE EXPENSE OF REDUCE THE EFFECTIVENESS. FOR EXAMPLE INCREASED SHARING OF THE EEI SAC CAN SPUR EFFICIENCY THAT WILL PROVIDE INCREASED SECURITY RESULTING IN FEWER INCIDENCE AND LOWER OVERALL COST. SIMILARLY OPPORTUNITIES FOR STAKEHOLDER DEBATE MIGHT BE RETKPWARTED IN SOME SENSE AS INENTIOUS FICIENT BUT THE END RESULTS OF SUCH SUBSWREBGT MATTER EXPERT STAKEHOLDER INFORMED PROCESSES, ARE LIKELY TO BE MORE EFFECTIVE THAN DECISIONS MADE WITHOUT ADEQUATE STAKEHOLDER INPUT. SECOND APPA BELIEVES THAT COMMUNICATING DEFENSES AGAINST THOSE THREAT HEAT SHOCK SYSTEM BE A KEY PRIORITY FOR NERC. SO WHILE SO SECURITY INCIDENCES RESULT INDEED A LOSS OF LOAD IN 2018 IT IS ESSENTIAL TO REMAIN VIGILANT AGAINST THESE THREATS AND INSURE THAT STAKEHOLDER VS ACCESS TO RELIABILITY THREAT INFORMATION AND MITIGATION STRATEGIES. THANK YOU FOR THIS OPPORTUNITY AND I LOOK FORWARD TO YOUR QUESTIONS.

GOOD MORNING AND LET ME CLARIFY THAT I WILL SPEAKING AS A MEMBER OF THE ISO, RTO COUNCIL RATHER THAN ON BEHALF OF, THE INTERNATIONALINATE AND YOU ARE DIVERSE NATURE OF THE ORGANIZATION MAKE ITS DIFFICULT FOR US TO REACH AGREEMENT IN A TIMELY FASHION ON JOINT COMMENTS. I CAN TELL YOU THAT MANY OF MY COUNTERPARTS SHARE MY THOUGHTS ON THESE ISSUES. I'M ENCOURAGED BY YOUR INTEREST IN REVIEWING THE ERO ACTIVITIES IN THIS CONFERENCE, AND CEO OF STP SINCE BEFORE THE PASSAGE OF THE ENERGY AND POLICY ACT OF 2005. I CAN TELL YOU IT'S BEEN INTEREST AS WE MATURED THROUGH THE MOVE TO MANDATORIA STORY TELLERS--MANDATORY PROCESS, AND I PREDICTED THIS WOULD BE UNNECESSARILY CLUMS SKPE BAKUGAN IN MANY WAYS IT HAS BEEN, BUT THERE'S BEEN HUGE MATURATION IN BOTH THE OPERATION AND PLANNING AS SPECT OF YOUR THE STANDARDS. BUT I BELIEVE THERE'S STILL SIGNIFICANT WORK ON THIS CYBER ASPECT OF THE STANDARDS. AND FRANKLY NOTHING COULD BE MORE IMPORTANT. CYBER REMAINS OUR SINGLE BIGGEST THREAT FOR MY COMPANY AND FOR OTHER ISO RTOS. AND I BELIEVE THERE ARE THREE SPECIFIC AREAS THAT NEED MUCH MORE FOCUS. FIRST, THE STANDARDS DEVELOPMENT PROCESS IS CONTINUALLY OUTPACED BY TECHNOLOGY AND THE CHANGING THREAT VECTOR. WE ALL KNOW THAT AND WE SIMPLY NEED TO SPEED THE PROCESS OF MODIFYING THE STANDARDS UP. POLICY WILL NEVER KEEP UP WITH TECHNOLOGY, WE ALL KNOW THAT, WE NEED TO RECOGNIZE THAT BUT THE STANDARDS DEVELOPMENT PROCESS IS GOING TO HAVE TO SPEED UP. SECOND, AT TIMES, THE VARYING INTERPRETATIONS OF WHAT COMPLIANCE MEANS BY THE REGIONAL ENTITIES IS VARIED. BOTTOM LINE THAT CREATES CONFUSION FOR US AND I MEAN JUST CREATES PROBLEMS. WHILE I APPRECIATE NERC AND THEIR EFFORTS TO HARMONIZE THE STANDARDS AND THEIR INTERPRETATION OF THE STAND STANDARDS, I WILL SAY AFTER 12 YEARS THIS AREA REMAINS ELUSIVE TO SAY THE LEASE AND TREURD THIRD, PRIORITY EFFORTS IN MY VIEW ARE SLOWING THE MATURATION OF BOTH THE STANDARD DEVELOPMENT PROCESS AND THE CONSISTENCY AND INTERPRETING THE STANDARDS. I WOULD HIGHLY ENCOURAGE NERC AND THE REGIONS TO TAKE FULL ADVANTAGE OF THE OUTREACH AND,A SURANCE COMPONENT OF THE CMEP. THAT COLLABORATIVE APPROACH IS FAR MORE BENEFICIAL THAN FOCUSING ON THE ENFORCEMENT ASPECT WHEN IT COMES TO COMPLIANCE. INTERNAL CONTROLS IN MY VIEW ARE THE BEST AND MOST APPROPRIATE WAY TO MOVE THOSE TOWARD A MORE RELIABLE BULK ELECTRIC SYSTEM. SWITCHING GEARS TO A FEW QUESTIONS YOU PRESENTED TO OUR PANEL, SPP BELIEVES THAT THE FUEL COMMRI SYSTEM SHOULD BE PART OF THE SYSTEM FOR CONTINGENCY ANALYSIS PURPOSES AND I WILL ALSO SAY THAT WE BELIEVE CAPACITY OBLIGATIONS NEED TO MOVE UNDER NERC'S PERVIEW RATHER THAN BE UNDER THE INDIVIDUAL PURVIEW OF THE REGIONS, I KNOW THEREYA A LOT OF DISAGREEMENT AMONG THAT AND THE PARTIES BUT THAT'S OUR BELIEF. AND LASTLY WE FULLY SUPPORT THE EISAC, ALL THE INDUSTRY NEEDS TO PARTICIPATE IN THAT. THE ONLY TECHNOLOGY TRANSFER THEY WOULD SIMPLY ADD IS FOR THE INFORMATION COMING OUT OF THE EISAC TO BE MORE ACTIONABLE. WITH THAT I LOOK FORWARD TO YOUR QUESTIONS. THANK YOU. GOOD MORNING I'M PETER BALASH SENIOR ECONOMIST WITH THE DEPARTMENT OF ENERGY NATIONAL ENERGY TECHNOLOGY LABORATORY. I WOULD LIKE TO THANK THE COMMISSION FOR THE OPPORTUNITY TO SPEAK TODAY. DUE TO REGULATORY PRESSURE, PLENTIFUL SUPPLIES OF NATURAL GAS AND STATE LEVEL POLICY INTERVENTIONS, THE POWER SYSTEM HAS BEEN IN GREAT TURMOIL FOR THE PAST DECADE AND THESE CHANGES ARE NOT LIKELY TO, BAIT ANYTIME SOON BUT RATHER INCREASE. RELIABILITY WITHIN MANY REGIONS OF THE U.S. BULK ELECTRICITY SYSTEM IS BECOMING MORE VULNERABLE WITH THE AMOUNT OF FUEL SECURE GENERATION, NAMELY COAL AND NUCLEAR POWER WHICH CAN SUSTAIN LONG-TERM SUPPLY DISRUPTIONS IS SIGNIFICANTLY DECREASING. WHILE SUBSTANTIAL NATURAL GAS CAPACITY IS COMING ONLINE. IT'S FUEL SECURITY IS UNCERTAIN AS ONSITE FUEL STORAGE IS EXPENSIVE AND WOULD REQUIRE A LARGE FOOTPRINT TO BE SERVABLE. MUCH OF THE REMAINING GENERATION VOID HAS BEEN FILL WIDE VARIABLE ENERGY RESOURCES WHICH OFFER FAR LESS CAPACITY AND AND ARE INTERMITTENT. DURING EXTREME WEUBTER WEATHER, THE LACK OF PIPELINE CAPACITY AND RELIABLE RESOURCES LED OPERATORS IN THE NORTHEAST TO BURN OIL FOR POWER, DURING REPEATED COLD WEATHER EVENTS WITH MANY PLANTS RUNNING OUT OR NEARLY OUT OF OIL IN INCREASING SHORT-TERM EMISSION TO RETIRE THEN THOSE OF CONTROL FIRED UNITS. A FUNDAMENTAL PRINCIPLE OF FERC REGULATED MARKET SYSTEM FUEL NEUTRALITY. HOWEVER, SINCE THOSE CHANGES BEGAN IN THE 1990S, OTHER POLICY GOAL VS EMERGED INCLUDING RENEWABLE PORTFOLIO STANDARD AND FEDERAL TAX CREDITS FOR WIND AND SOLAR GENERATION THAT DRIVE THE AMOUNT OF RENEWABLE GENERATING CAPACITY WITHIN STATES WITHOUT THE CHECK AND BALANCE OF RELIABILITY. WE ENCOURAGE THE COMMISSION TO RECOGNIZE THE SPIRIT CONSTRUCT WAYS THAT WILL INSURE THAT THE NATION'S BULK POWER SYSTEM REMAINS OPERABLE AND RESILIENT IN THE FACE OF PREDICTABLE EVENTS. TO FURTHER RECOMMEND THAT THE RETROSPECTIVE DURATION OF THE STATE OF RELIABILITY REPORT CAN FAR BEYOND FIVE YEARS TO REACH BACK TO A MORE STABLE PERIOD AND THAT THE ELECTRIC RELIABILITY ORGANIZATION ANALYSIS INCLUDE NEAR MISS EVENTS IN ITS SCOPE AND PREVENTS SUCH EVENTS FROM CASCADING MORE. THANK YOU.

THANK YOU ALL FOR YOUR PARTICIPATION AND QUALITY PRESENTATIONS. ONE OF THE IMPORTANT TRENDS THAT I POINTED OUT ON A NUMBER OF OCCASIONS IS THAT THE MATURATION OF THE OPERATIONS IS PLANNING STANDARDS OVER THE PAST SEVERAL YEARS HAS ALLOWED NERC TO SPEND MORE TIME ON EMERGING RISKS THAT THE INDUSTRY HASN'T HAD HISTORICALLY HAD AS MUCH EXPERIENCE WITH SUCH AS SUPPLY CHAIN SECURITY, FUEL SECURITY AND RESIL WRENS AND EMP AND I THINK IT'S GREAT THAT NERC HAS BEEN FOCUSING ON THIS AND A NUMBER OF TASK FORCES LOOKINGA THE THESE ISSUES. MY QUESTION IS THIS, ONCE THE TASK FORCE IS DONE WITH ITS REPORT ON ONE OF THESE EMERGING ISSUES, HOW DO WE MAKE SURE THAT ALL THAT GOOD WORK DOESN'T JUST WIND UP SITTING ON A SHELF SOMEWHERE BUT THAT WE KEEP BUILDING ON IT AND MAKING PROGRESS. MAYBE GYM I'LL START WITH YOU AND OPEN IT UP TO OTHERS.

I'LL MAKE A FEW COMMENTS THAT SUGGESTED ALSO, AND IF THAT'S AOEUBLT AND WITH THE STRONG DEGREE OF STAKEHOLDER ENGAGEMENT IN ALL THIS WORK, SO MY SENSE OF THAT IS IN ADDITION TO KIND OF HAVING THE TASK FORCE WORKING ON THE ISSUE, YOU ARE ALSO BUILDING COMMITMENT TO THE SOLUTIONS IN AN EVANGELICAL CAPABILITY TO SOCIALIZE THE FINDINGS AND HAVE THAT SPREAD THROUGH INDUSTRY. MANY OF THESE RESULT IN INDUSTRY GUIDELINES THAT CAN BE THE PRECURSOR TO THE STANDARD IF APPROPRIATE, OR OTHER ALERTS, INDUSTRY EDUCATION, SO FOGGER AROUND ISSUES, IT'S CLEARLY NOT IN ANYONE'S INTEREST OR IN OUR ASPERRATION TO DID INTERESTING WORK AND HAVE IT SIT ON THE SHELF. SO FOR US THE WHOLE GAME HERE IS IMPACT INVOLVING BEHAVIOR AND CHANGES PEOPLE MAKEOT SYSTEM. DO YOU WANT TO--

I THINK YOU SAID IT WELL. ESPECIALLY THE GROUPS WE ARE TALKING ABOUT AND THE AREAS WE'RE TALKING ABOUT, THE WHOLE THOUGHT IS DO SOME OF THE BASIC GROUND WORK, WHAT ARE SOME OF THE BETTER PRACTICES, MAKE SURE THAT WE'VE THEN DOCUMENT THEM AND GUIDELINES THAT ARE POSTED ON OUR WEBSITE ARE APPROVED BY THE COMMITTEE SO OF COURSE, BROADER SOCIALIZATION HAS A LOT MORE VISIBLE AND THEN OF COURSE, YOU KNOW YOU HAVE TO LOOK AT RISKS IN DIFFERENT LIGHT, FOR EXAMPLE IF SOMETHING IS MODERATELY IMPACTFUL AND LIKELY, THEN MAYBE THAT'S NOTHING YOU NEED TO LOOK AT, WHAT IS OUR TOOL KIT LOOK LIKE AS JIM MENTIONED WE HAVE ALERTS, WE HAVE LESSONED LEARNED WE HAVE GUIDELINES WE HAVE STANDARDS SO IT'S MODERATE AND LIKELY TO HAPPEN, MAYBE WE FOCUS ON WHAT IT'S ON BUT UNLIKELY AND HIGH IMPACT, HIGH SEVERE MITRAL ERITY THEN MAYBE AGAIN WE LOOK AT THE STANDARD BUT THEN AGAIN IF IT'S LESS RISKY, LIKELY BUT MAYBE LOW IMPACT BUT THEN YOU LOOK AT OTHER TOOLS BUT WE USUALLY AS JIM SAID USE THESE IN A TANDEM WAY SO THE GUIDELINES START SETTING THE STAGE AND AT THE RIGHT TIME STANDARD [INDISCERNIBLE]. SO.

SO JUST ZERO IN A BIT ON THAT, SPEAKING OF RISK TO THE INDUSTRY DOESN'T HAVE A LOT OF EXPERIENCE WITH EMP, HAS EMERGED AS AN IMPORTANT PRIORITY AS EVIDENCE BY THE ADMINISTRATION'S RECENT EXECUTIVE ORDER, I KNOW NERC HAS A TASK FORCE ON THAT ISSUE SO I'M INTERESTED JIM IF YOU COULD TALK ABOUT THE GOAL OF THAT TASK FORCE AND WHETHER THAT'S GOING TO RESULT IN ACTIONAL INFORMATION FOR THE INDUSTRY?

YEAH, SO OBVIOUSLY WE KNEW THIS WAS COMING SO WE PREPOSITIONED WITH OUR INDUSTRY STAKEHOLDERS A WORKING GROUP THAT WOULD BE READY TO RECEIVE THE REPORT, DIGEST THE SCIENCE BEHIND IT IS START TO WORK TOWARD WHAT THE APPROPRIATE REGULATORY RESPONSE IS. OUR SENSE IS THAT TASK FORCE WILL TAKE ABOUT SIX MONTHS, TO WORK THROUGH THE RESEARCH AND THE OPPORTUNITIES AND I WOULD SAY THERE'S A REASONABLY HIGH LIKELIHOOD THAT BY THE END OF THIS YEAR, WE WILL HAVE A SAR PREPARED THAT WOULD OUTLINE THE PARAMETERS FOR A NEW STANDARD SURROUNDING EMP. CAN'T SPECULATE ON WHAT THIS WILL BE BUT THAT'S THE TIME PRIME WORE WAORBGING AGAINST.

THANK YOU. NICK, YOU HAD TOUGH WORDS IF ARE THE SIP STANDARDS PARADIGM IN YOUR PREPARED TESTIMONY, IN PARTICULAR, YOU KNOW THE CONCERNS ABOUT CONSISTENCY OF ENFORCEMENT ACROSS REGIONS AND YEARS OF PARTICIPATION IN SOME PROJECTS WITHOUT RESULTS, HOW DO WE CREATE THAT BETTER CONSISTENCY IS ENFORCEMENT AND MAKE THE STANDARDS DEVELOPMENT PROCESS RESULTS DRIB AND NOT JUST A BUREAUCRATIC EXERCISE?

WELL, FIRST CREATE THE STANDARDS SO THAT THEY'RE MORE FORWARD LOOKING IN TERMS OF COMPLIANCE. THAN LOOKING IN THE REAR VIEW MIRROR AT WHERE ENTITIES HAVE BEEN. AND TWO,--PENALTIES ARE FINE WHEN THERE ARE BAD ACTORS BUT THE FOCUS ON ENFORCEMENT AS GONE UP. IT'S RATCHETING UP AND THAT'S CREATING LESS COMMUNICATION IN THE AUDIT PROCESS, LESS COMMUNICATION BETWEEN OURSELVES AND THE REGIONAL ENTITIES. SBP'S COLLABORATIVE ORGANIZATION, WE BELIEVE IN THE POWER OF COLLABORATION. AND I THINK OUR FOCUS ON ENFORCEMENT HAS BEEN BECAUSE OF THE FEW BAD ACTORS HAVE MOVED THOSE INTO THAT ARENA. I BELIEVE THE VAST MAJORITY OF THIS INDUSTRY WANTS TO DO THE RIGHT THING AND WHEN THEY CAN UNDERSTAND THE INTENT BEHIND THE STANDARDS AND COLLABORATIVE AAGREE ON WHAT COMPLIANCE MEANS, THEN WE'RE GOING TO BE BETTER OFF AND COMPLIANCE IS GOING TO HAVE TO BROADEN BECAUSE THE THREAT VECTORS ARE CHANGING SO FAST. TECHNOLOGY IS AVAILABLE TODAY THAT WE BELIEVE IS MORE SECURE. MEMBERS OF AUDIT TEAMS HAVE BELIEVED WE WERE COMPLIANT, OTHERS BELIEVE WE'RE NOT COMPLIANT WITHSTAND ARDS THAT ARE OLD, YET WE'VE BEEN IN THIS STANDARD DEVELOPMENT PROCESS TO ADDRESS THIS ISSUE FOR TWO YEARS AND THERE'S NO END IN SIGHT. SO IT'S--SOMETHING'S GOTTA GIVE ON THAT. WE NEED TO BE FOCUSED ON SECURITY AND NOT JUST COMPLIANCE AND SECNOLOGY WILL ENABLE US TO DO THAT. BUT WE'RE GOING TO HAVE TO EMBRACE THAT IN A MORE QUICK FASHION.

ANYONE ELSE HAVE THOUGHTS ON THAT PARTICULAR ISSUE?

I HAVE A SLIGHTLY DIFFERENT VIEW THAN NICK BUT I APPRECIATE YOUR COMMENTS. WE'VE BEEN ABLE TO WORK WITH OUR REGIONS TO DEVELOP MORE OF A COLLABORATIVE APPROACH TO COMPLIANCE WITH THE SIP STANDARDS. I THINK RECENT ENHANCEMENTS SUCH AS SELF-LOGGING REALLY SHOW A LOT OF PROMISE, THE COMPLIANCE EXCEPTION PROCESS WHICH ALLOWS FOR US TO BASICALLY SELF-IDENTIFY ISSUES, MITIGATE THEM QUICKLY WITHOUT A PENALTY THREAT ARE VERY HELPFUL AND ALLOW US TO SORT OF, YOU KNOW LOOK AT THE BOTTOM OF THIS PYRAMID AND BE OPEN AND HONEST WITH OUR ISSUES. I DO THINK THERE HAVE BEEN ISSUES WITH CONSISTENCY BUT I THINK NERC IS WORKING ON THAT TO THE BEST OF THEIR ABILITY. YOU KNOW THE ISSUE THOUGH WITH THE STANDARD IS, THERE'S ALWAYS A BALANCE BETWEEN BEING PRESCRIPTIVE AND BEING FORWARD LOOKING OR RISK BASED AND I THINK THAT THE PHILOSOPHICAL ISSUE THAT WE'RE WORKING WITH IN THE INDUSTRY TODAY.

THANK YOU. I WANT TO SWITCH GEARS TO THE ISSUE OF RESILIENCE. I'VE NOTE OFFICE OF DIVERSITY A NUMBER OF OCCASIONS MY APPRECIATION FOR THE IMPORTANT WORK THAT ISO NEW ENGLAND AND MORE RECENTLY PJM HAVE DONE TO EVALUATE THE ISSUE OF FUEL SECURITY. PETER THE ISSUE OF FUEL SECURITY IS ONE YOU'VE SPENT A GREAT DEAL TIME EXAMINING SO FOR THOSE RTOS AND ISOS THAT HAVE NOT TAKEN PROACTIVE STEPS TO EXAMINE THE ISSUE LIKE ISO NEW ENGLAND AND PJM, DO HAVE YOU ANY ADVICE ON WHERE THEY SHOULD START THAT EXAMINATION AND THEN WHERE TO PROCEED FROM THERE.

TWO GENERAL COMMENTS, ONE THEY SHOULD EXAMINE THE LEVEL OF TO WHICH THEIR SPACE HEATING MARKETS DEPENDS ON NATURAL GAS AND TO THE DEGREE TO WHICH THEY ARE SUSCEPTIBLE TO NATURAL TKPWAZ COMSUMPTION DURING THE WINTER MONTHS SO FOR THE NORTHERN REGIONS BECAUSE WHEN THAT HAPPENS THERE'S A LARGE SHIFT IN THE SUPPLY CURVE OF NATURAL GAS FROM POWER GENERATION TO THE HOME HEATING MARKET AND TO THE MICHELLE SPACE HEATING MARKET. AS A RESULT THAT NATURAL GAS IS NOT AVAILABLE TO THE POWER GENERATION. WHEN THAT HAPPENS IF THERE'S A PIPELINE CONSTRAINT, THEN THE PRICE CAN SPIKE FOR NATURAL GAS AND IF NATURAL GAS IS THE FUEL THAT SETS THE PRICE FOR YOUR REGION THEN YOU WILL EXPERIENCE LARGE INCREASES IN THE PRICE OF ELECTRICITY. SECONDARILY, IF YOUR REGION HAS--WELL, LET ME BACK UP. THAT CAN BE EMELIORATED WITH NATURAL GAS STORAGE, NATURAL GAS STORAGE IS NOT EXPENSIVE HOWEVER I HAD CONVERSATIONS WITH A PROFESSOR AT CARNEGIE MELON AND THAT COULD BE EMELIORATED WITH THE ONSITE STORAGE WHICH WOULD INCREASE THE CAPITAL COST FOR NATURAL GAS [INDISCERNIBLE] ON THE ORDER OF ABOUT 15%. HOWEVER THAT WOULD BE A PRICE TO PAY FOR RELIABILITY AND RESILIENCE FOR MOST WEATHER [INDISCERNIBLE]. TURNING TO INTERMITTENT RESOURCES IN JANUARY 28 OF THIS YEAR WIND COMPRISED 47% OF PEAK OUTPUT IN SBP AND 17% IN [INDISCERNIBLE]. TWO DAYS LATER IT HAD COLLAPSED. SO, IN EACH REGION LOST 11 GIGAWATTS OF WIND OUTPUT BETWEEN THE PEAK ON THE 28TH AND TWO DAYS LATER. IF THAT'S--WHAT FILLED THE VOID WAS COAL AND NATURAL GAS RESOURCES. COAL GENERATION INCREASED, NATURAL GAS LOAD FOLLOWED AND INCREASED. BUT WITH THE POLICY DIRECTION OF CERTAIN AREAS, IF THOSE RESOURCES NO LONGER BECOME AVAILABLE, THEN YOU WOULD HAVE TO RELY EITHER ON A VERY LARGE WIDE AREA NETWORK OR VAST AMOUNTS EVER BATTERY STORAGE AND BATTERY STORAGE TO DATE IS ONLY AT FOUR HOURS OF DISCHARGE AND YOU TAKE THE CAPACITY OF THE INTERMITTENT RESOURCE AND MULTILIE BY SIX BY THE CAPACITY YOU WOULD NEED TO BACK THAT UP SECURELY WITH STORAGE. SO AS A RESULT THERE'S MANY WAYS YOU CAN LOOK AT HOW HAVING A TRULY RELIABLE SYSTEM IN RESILIENCE WILL INCREASE YOUR CAPITAL COST OF OPERATIONS.

THANK YOU. TIM, YOU MENTIONED IN YOUR TESTIMONY, OUR REPS AND THE OTHER REGIONS ARE WORKING ON RESILIENCE METRICS AND TOOLS, COULD YOU ELABORATE A BIT ON THOSE EFFORTS AND OTHER WAYS WE COULD HAVE NERC AND THE REGIONS WORKING COLLABORATIVELY WITH REGISTERED ENTITIES WITH ON THE ISSUE OF RESILIENCE.

YES, SIR SO WE'RE VERY EXCITED ABOUT A PROJECT WE'VE BEEN WORKING ON ON WITH CREDSI, WHICH STANDS FOR CYBER ENERGY RESILIENCE CONSORTIUM, IT'S ACADEMIA, RELIABILITY, AND PORTIONS ARE FUNDED BY THE DEPARTMENT OF ENERGY SKPE BAKUGAN ONE OF THE PRODUCTS THAT CAME OUT FOR MY STAFF IS A WAY TO MEASURE YOUR CYBER RESILIENCES AND DONE BY TRIED AND TRUE METHODS WHICH IS RESOURCEFULNESS REPETTIVENESS RESILIENCE AND REDUNDANCE. IT'S A SELF-ASSESSING TOOL WE PROVIDE FREE TO THE INDUSTRY. IT COVERS 28 DIFFERENT CAT TKPW-RYS ACROSS THOSE FOUR R-DOMAINS WE TALKED ABOUT. WE HAVE DONE TESTING AND THE RESULTS ARE GOOD. IT TAKES 30 MINUTES TO FIVE HOURS TO COMPLETE THE ASSESSMENT DEPENDING ON WHICH EXPERT IS COMPLETING THE QUESTIONS AND IT HIGHLIGHTS FOR YOU WHERE YOUR STRENGTHS ARE FROM A RESILIENCESY STANDPOINT AND WHERE YOU HAVE OPPORTUNITY. WE ARE EXCITED TO ROLL THAT OUT. WE WILL PARTNER WITH NERC WHEN IT'S AVAILABLE TO BE READY TO BE DEPLOYED VRO WIDE.

IN ADDITION TO RESIL WRENS, PHYSICAL AND CYBER SECHIITY REMAIN A TOP RIPORRITY HERE AT THE COMMISSION, AND OUR SECURITY INVESTMENT TECH UNTILICAL CONFERENCE SEVERAL MONTHS AGO, THE NEED TO CONTINUE COORDINATING WITH FEDERAL AGENCIES INCLUDING DOE AND DHS WAS CLEAR. MISS STERLING YOU HIT A SIMILAR THEME IN YOUR PREPARED TESTIMONY ABOUT COORDINATING WITH DOE AND DHS, IN YOUR VIEW DOES THAT COORDINATION MAINLY INCLUDE INFORMATION SHARING OR ARE THERE MORE SPECIFIC ACTIONABLE ITEMS WE SHOULD BE COORDINATING ON AND HAPPY TO START WITH YOU AND OPEN IT UP TO OTHERS.

WELL LET ME SAY ABOUT THAT BECAUSE I DO THINK THAT COORDINATION IS KEY, AND INFORMATION SHARING IS REALLY IMPORTANT. WE NEED THE TECHNICAL EXPERTS OF MANY FEDERAL AGENCIES TO BE ABLE TO COORDINATE AND TALK ABOUT THEIR PARTICULAR VIEW POINT FOR THESE ISSUES. YOU KNOW FOR US, AS AN ELECTRIC COMPANY, WE JUST DON'T DEPEND ON ANY ONE SOURCE OF INFORMATION AND WE DON'T DEPEND ON JUST THE SIP STANDARDS TO DEFINE OUR OVERALL CYBERSECURITY POTTURE SO TO THE EXTENT WE ARE EARLY AND ACTIONABLE INFORMATION AS YOU SAY, I THINK IT'S REALLY IMPORTANT. SO I THINK INFORMATION SHARING IS A TOP PRIORITY BUT AS WE MOVE THROUGH THESE CONVERSATIONS OTHER PRIORITIES WILL CERTAINLY BE IDENTIFIED?

ANYBODY ELSE KACCT IRB TO CHIME IN ON THAT?

ONE THOUGHT I HAD IS THAT JUST OBSERVING THE ISSUES AS THEY COME ON TO OUR SYSTEM AND THEN REACTING TO THEM, I WORRY A LITTLE BIT THAT EVENTUALLY THEY BECOME KIND OF A STEADY STREAM SO HOW DO WE STEP BACK AND DO ALL OF THE EXERCISING AND MAKING SURE WE HAVE--WE ARE PUTTING IN FRONT OF THE ATTACKERS, ASYSTEM THAT'S MORE ROBUST, MORE SEGMENTED SO AS WE ADD MORE TECHNOLOGY, WE ARE ALSO DERISKING THE SYSTEM. MAKING IT SEPARATE AND SO LOOKING FROM A PLANNING PERSPECTIVE, BUILDING A SYSTEM THAT IS MORE ROBUST AND DEFENDABLE AND THEN ONCE YOU KNOW YOU'VE BEEN ATTACKED, THEN OF COURSE PREPOSTURING AND THEN BEING ABLE TO COME BACK AFTERWARD, I THINK THOSE ARE ALL AREAS THAT WE NEED TO KIND OF BE FOCUSING OUR ATTENTION ON ALONG WITH THE SITUATION AWARENESS.

THANK YOU. ON THE ISSUE OF CYBERSECURITY, SUPPLY CHAIN SECURITY HAS BEEN A MAJOR CONCERN OF MINE WHICH IS ONE REASON I STRONGLY SUPPORTED THE APPROVAL OF THE NERC SUPPLY CHAIN STANDARD. MR. CASHEN, IN YOUR TESTIMONY, YOU MENTIONED THE VENDORS CERTIFY THEIR SECURITY, NONAPOPTOTIC THE UTILITY, GIVEN WE DON'T HAVE JURISDICTION OVER THE VENDORS HOW WOULD YOU SEE A SYSTEM LIKE THAT WORKING?

WELL I THINK WE'VE BEEN IN DISCUSSIONS WITH NERC AS WELL AS OTHER ORGANIZATIONS. FOR EXAMPLE, AS YOU JUST MENTIONED, YOU KNOW OUR FEDERAL PARTNERS, YOU KNOW I KNOW THAT A LOT OF OUR FOLKS REALLY LOOK TO SAY FED RAMP WITH RESPECT TO LOOKING FOR SOME SORT OF CERTIFICATION ON THE CLOUD AND THAT'S SOMETHING THAT I KNOW YOU WILL HEAR ABOUT MORE ON THE SECOND PANEL, SO THAT'S JUST, YOU KNOW ONE EXAMPLE OF THAT, BUT I THINK THAT YOU KNOW WITH RESPECT TO SUPPLY CHAIN, YOU KNOW WE DO RECOGNIZE AND I THINK THAT'S BEEN RECOGNIZED WITHIN THIS CONFERENCE LAST YEAR THAT YOU KNOW THERE IS SORT OF A THIRD LEG TO THE STOOL WITH THE VENDORS AND THAT'S JUST IT. I THINK LOOKING TO SOME KIND OF CERTIFICATION PROGRAM WITH NERC, SOME KIND OF IDEA WHERE THEY CAN ACCEPT THE WORK OF OTHERS AND THERE ARE AS I MENTIONED OUR ORGANIZATION SUCH AS FED RAMP WHO WILL FIT INTO THAT ROLE. WE FEEL THAT THAT'S IMPORTANT AND NAIT CAN GO TO A POINT OF A LOT OF ANALYSTS HAVE MADE IS THE CHANGE IN TECHNOLOGY, THERE HAVE TO BE THE FLEXIBILITY TO HAVE A PROGRAM LIKE THAT AND HAVE SOME KIND OF VERIFICATION FOR THE VENDORS.

YOU ALSO MENTIONED THE WHYED OF DEVELOPING INCENTIVES FOR GOOD RISKS AND CONTROL ASSESSMENT, CAN YOU JUST COLLABORATE ON THAT WHAT MEANS?

I'M NOT SURE THE CONTEXT OF I GUESS THE REMARK BUT I BELIEVE THAT YOU KNOW WHAT WE'RE LOOKING FOR IS A PROGRAM WHERE COMPANIES HAVE THAT FLEXIBILITY SO THAT THEY FEEL THEY CAN OPERATE IN A WAY THAT IS CONSISTENT WITH HOW THEY REALLY WANT TO MOVE FORWARD WITH NEW TECHNOLOGIES.

THANK YOU ALL. COMMISSIONER LAFLEUR?

THANK YOU VERY MUCH, TERRIFIC PRESENTATIONS. I DON'T HAVE A QUESTION BUT I WANT TO THANK JIM, MARK, AND JENNIFER ON YOUR FOCUS ON THE EMP REPORT, I WAS ENCOURAGED TO SEE THE REPORT AND TIMELINE FOR ANALYSIS AND PILOTING COMING OUT OF IT. I WOULD ENCOURAGE PROMPT ACTION TO TAKE IT TO A SAR OR AN ACTIONABLE SET OF STEPS AND I WILL CERTAINLY BE CONTINUING TO WATCH IT ALL FROM THIS SEAT ON THAT TIMELINE. I WANT TO FOCUS IN ON FIRST ON EXTREME WEATHER EVENTS. THE MOST RECENT STATE OF RELIABILITY REPORT SHOWED THAT RESPONSE WAS GOOD LAST YEAR BUT OF COURSE, ALTHOUGH WA TALK AN AWFUL LOT ABOUT CYBERSECURITY AND SO FORTH, ALL VERY IMPORTANT TO TALK ABOUT, EXTREME BLOOD SUGAR IS THE BIGGEST CAUSE OF LOAD LOSS AND RELIABILITY ISSUES THAT CUSTOMERS SEE AND CLIMATE CHANGE SCIENCE SUGGESTS WE WILL BE SEEING MORE OF IT, NOT LESS OF IT, WE'RE CERTAINLY SEEING THE WILDFIRES IN THE WEST, THE HURRICANES IN THE SOUTHEAST, EXTREME COLD AND BLIZZARDS IN THE NORTHEAST, AND I WANT TO ASK, YOU KNOW HOW--WHAT NERC AND THE ERE CAN DO TO HELP OUR COLLECTIVE PREPARATION AND RESPONSE BECAUSE THIS SEEMS TO BE A FEATURE--ALTHOUGH WE'RE RYING TO WORK ON THE MITIGATION OF CLIMATE ISSUES--BUT IT SEEMS TO BE A FEATURE THAT EVERY OTHER YEAR YOU HAVE A HUNDRED YEAR STORM. SO WHAT DO I SEE YOUR ROLE IN THE HELPING THE INDUSTRY RESPOND TO THIS?

SPECIFICALLY IN TERMS OF THE POLEAR VORTEX, WE DID IMPLEMENT TOOLS BUT IN ADDITION WE SENT EXPERTS FROM OUR STAFF TO MEET OUT INTO THE FIELD TO MEET WITH PLANT OWNER/OPERATORS TO IDENTIFY AREAS WHERE THE WEATHERIZATION EFFORTS WERE NOT SUFFICIENT. AND THAT'S BEEN A FANTASTIC PROGRAM. WE'VE DONE IT EVERY YEAR SINCE THEN, AND EVERY YEAR WE FIND VERY, VERY INNOVATIVE WAYS THAT PLANT OWNERS AND OPERATORS HAVE ADDRESSED THIS AND WE DISSEMINATE THOSE LESSONS ACROSS THE OTHER PLANS. SO DOING THINGS LIKE THAT, GETTING HANDS ON, BEING TARGETED, UNDERSTANDING RISKS WE IDENTIFY HIGHEST PRIORITY PLANTS ISSUES THOSE THAT HAVE THE BIGGEST STRUGGLES AND AND THE OTHER THING WE DID WAS PARTNER WITH RTOS TO HAVE MARKET PROVISIONS PUT IN PLACE THAT REWARDED THE KIND OF BEHAVIOR WE'RE LOOKING FOR AND TO DETER THE KIND OF BEHAVIOR WE WEREN'T LOOKING IF AND WE'RE IN A UNIQUE POSITION BECAUSE WE'RE TOTALLY COMPRISED OF RTOS AND THAT'S BEEN A VERY SUCCESSFUL IN DEALING WITH US IN WITH ISSUES. AND CAPACITY AND SO FORTH.

JIM?

MAKE AN OBSERVATION AROUND THE MAJOR SEVERE WEATHER EVENTS THAT WE SAW LAST YEAR THE TWO MAJOR HURRICANES, ONE OF THE PRIVILEGES I HAVE AND THE ROLE I'M IN IS PARTICIPATING ON THE ESAC, AND I HAVE TO TELL YOU, AND I DON'T KNOW WHAT FERC'S VISIBILITY IN THE PRESTORM PROCESS AND THE ONGOING STORM CALLED AND MOST OF THIS IS ACCORD PLATED THROUGH EI, BUT--MOST OF THIS IS COLLABORATED THROUGH EI, BUT MOST THE LEADERS AMONG THE AFFECTED UTILITIES THAT SUPPORT OUR GOVERNMENT PARTNERS IN TERMS OF CLEARING AIR SPACE FOR DRONES, PROVIDING VEHICLE TO GET THROUGH HIGH WATER, ALL THOSE ISSUES, THE ENVIRONMENT WAIVERS IS REQUIRED IT'S REALLY AN EXTRAORDINARY KIND OF A THING OF BEAUTY TO SEE HOW WELL COORDINATED THAT IS, PRESTORM, DURING, AND POST RECOVERY. SO FOR THE EVENTS COMING THE INDUSTRY HAS AN EFFECTIVE PROCESS FOR COORDINATION BOTH AMONGST ITSELF AND THE MUTUAL ASSISTANCE PROGRAM BUT WITH OUR PARTNERS THAT ARE SO CRITICAL TO BEING ABLE TO MAKE THE RESTORATION AND THE IMPACT OF THE STORMS DE MINIMUS AS POSSIBLE.

I MEAN, YOU'RE ABSOLUTELY RIGHT AND INDUSTRY HAS ALWAYS DONE ITS BEST WORK IN STORMS FOREVER. WE'VE ALWAYS SAID IF PEOPLE--EVEN IN BIG HURRICANES WE HAD THE FEWEST LOSS TIME ACCIDENTS AND IF WE COULD MAKE IT LIKE THERE WAS A HURRICANE EVERY DAY, IT WOULD BE THE BEST PERFORMANCE--I MEAN I REALIZE THAT'S NOT WHAT WE WANT BUT THERE ARE THINGS WE SHOULD BE DOING THINGS IN TERMS OF CONFIGURURATION OR HARDENING OR THE WAY WE LOOK AT THE GRID WITH THE GREATER WILDFIRES AND HURRICANES AND SO FORTH. I KNOW A LOT OF WORK IS GOING ON ON THE COAST BUT IS THIS SOMETHING WE SHOULD LOOK AT REGIONALLY OR A NATIONAL LEVEL.

WE DO GATHER INFORMATION AFTER THE FACT AS TIM INDICATED FOR EXAMPLE AND PUT TOGETHER PROGRAMS BE IT LESSONS LEARNED, GUIDELINES AND SO WHEN WE LEARN SOMETHING, AFTER THE FACT, GATHER INFORMATION, DO AN EVENTS ANALYSIS ISSUES POST OUR LESSONS LEARNED, MAYBE ALSO DRILL OUT TO A GUIDELINE AND ULTIMATELY IF IT'S SOMETHING THAT MAKES SENSE EVEN FURTHER TO A STANDARD, BUT WE WORK WITH OUR INDUSTRY PARTNERS ALL THE TIME TRYING TO UNDERSTAND WHAT HAS HAPPENED AND WHAT WE CAN LEARN FROM IT AND SHARE THOSE RESULTS WITH EVERYONE ELSE.

I THINK BY NATURE OF THIS OF THESE EVENTS THEY ARE REGIONAL EVENTS SO THE AMOUNT OF HARDENING THAT CAN BE DONE AND TYPES OF RECONFIGURURATION, THAT'S ALMOST BY DEFINITION REGIONAL, I CAN TELL YOU I'VE HAD INDUSTRY PRESENTATIONS THAT SHOW IMPRESSIVE PROGRESS IN BOTH REDUCING THE DURATION OF OUTAGES, REDUCING THE NUMBER OF OUTAGES OF THE SOME OF THE US IN FLORIDA, EAST COAST, TEXAS HAVE DONE A SIGNIFICANT AMOUNT OF STORM HARDENING AND THE METRICS SHOW IMPRESSIVE RESULTS AND I AGREE THE AMOUNT OF MUTUAL ASHES CYSTANCE CAN COORDINATION HAS INCREASED AND IMPROVED AND YOU KNOW IT IS BY NATURE A BIG FOCUS OF THE INDUSTRY.

THANK YOU. I JUST THINK THAT'S SOMETHING THAT NERC AND THE ERE'S CAN DO IMPORTANT SHARING LESSONS. WHAT I FOUND BOTH WHEN I WAS IN THE PRIVATE SECTOR BUT THEN SITTING IN THIS SEAT IS THAT THE LESSONS ARE ALWAYS APPLIED RIGHT WHERE THE PROBLEM WAS. IN THE WAKE OF HURRICANE SANDY WE'VE PINNED SO MUCH HARDENING IN NEW YORK AND NEW JERSEY AND SIMILARLY AFTER KATRINA BUT MAKING SURE THAT THE LESSONS ARE SPREAD TO OTHER REGIONS THAT MIGHT HAVE SIMILAR GEOGRAPHY BUT WE DIDN'T GET THE LAST STORM IS NOTHING THAT INY INY CAN DO. THAT LEADS SIDE WAYS TO MY NEXT QUESTION WHICH I WANT TO FOCUS A BIT ON WHAT'S DONE NATIONALLY AND WHAT'S DONE REGIONALLY. AND SEVERAL OF YOU TOUCH OFFICE OF DIVERSITY THAT BOTH JIM AND TIM TALKED ABOUT THE ROBUSTNESS OF THE R. E. MODEL AND ALINING THE R. E. SO THAT THEY WORK BETTER. JACK IN YOUR PREFILED TESTIMONY, YOU SUGGESTED THE NEED FOR DOING MORE THINGS REGIONALLY RATHER THAN NATIONALLY AND NICK, I THOUGHT I HEARD YOU SAY THE OPPOSITE, WE SHOULD BE LOOKING NATIONALLY AT SOME OF THESE CAPACITY ISSUES RATHER THAN THE REGIONS, MAYBE I'M CONFUSED, ON WHAT YOU SAID BUT I GUESS STARTING WITH JIM, HOW SHOULD WE LOOK AT WHETHER--ARE THERE THINGS WOO WE LEGITIMATELY SHOULD HAVE A REGIONAL STANDARD OR YOU KNOW THINGS GOING DIFFERENTLY IN DIFFERENT REGIONS OR ARE WE REPEATING OURSELVES TOO MUCH AND WE SHOULD DO MORE THINGS NATIONALLY.

IT'S A GREAT QUESTION AND I THINK THAT'S ONE THAT WE IMPLICITLY DEBATE QUITE FREQUENTLY. I THINK IN SOME CASES THERE'S A STRONG ROLE FOR REGIONAL STANDARD WE WILL TAKE ONE OF THE ISSUES THAT'S ON THE TABLE THAT WE'RE LOOKING AT RIGHT NOW IS THE CONNECTION OF THE NRC OUT THERE, THE WESTERN INTERCONNECTION IS STRUCTURED DIFFERENTLY THAN THE EASTERN CONNECTION, SO THE LEVEL OF COORDINATED INSIGHT INTO THE SYSTEM REQUIREMENT THERE IS MUCH DIFFERENT THAN IT IS IN THE EAST SO THERE'S A STANDARD, I BELIEVE IT MIGHT BE IN FRONT OF THE COMMISSION NOW.

YEAH.

TO MODIFY THE IRO STANDARDS TO INSURE THAT ONE THAT WE'RE--THE RCS ARE MODELING ALL THE [INDISCERNIBLE] SCHEMES IN THE WEST BECAUSE IT'S A CRITICAL COMPONENT OF HOW THE SYSTEM WORKS AND THAT THAT HAVE A COMMON MODEL OF THE *EURPT CONNECTION BECAUSE IT WORKS AS ONE MACHINE. THAT'S THE CASE WHERE THE REGIONAL STANDARDS ARE REQUIRED BUT THAT STANDARD WOULD NONAPOPTOTIC THE BE REQUIRE INDEED THE EAST BECAUSE IT'S NOT AS IMPORTANT FOR THE FLORIDA RC TO UNDERSTAND WHAT'S GOING ON IN NEW ENGLAND AS IT IS FOR SOMEONE IN THE SOUTHWEST TO KNOW WHAT'S GOING ON IN THE NORTHWEST. WHEN IT COMES TO THE EXECUTION OF PROGRAMS HOWEVER, AS NICK POINTED OUT WE HAVE LOTS OF HEAD ROOM IN OW WE DRIVE CONSISTENCY AND ALIGNMENT AND HOW THE REGIONAL ENTITIES AND THE BOOTS ON THE GROUND APPROACH PROBLEMS. THEY OBVIOUSLY HAD INDEPENDENT HERITAGE. MANY THESE ENTITIES WERE DOING THIS WORK BEFORE THE ERO WAS EVEN FORMED SO IT'S NO GREAT MYSTERY WHY WE HAVE EIGHT, DOWN SEVEN, SOON TO BE SIX WAYS TO DO THINGS. I THINK THE PROCESS THAT WE HAVE GONE THROUGH OVER THE LAST YEAR IN DEVELOPING THE ALIGN TOOL HAS REALLY BEEN PIVOTAL IN KIND OF OUR ABILITY TO DRIVE ALIGNMENT AND SO I KEEP QUOTING IN NUMBER AND I DON'T KNOW IF IT'S RIGHT SO SOMEONE WILL CORRECT ME ONE OF THESE DAYS BUT I THINK TO DATE WE'VE DONE SOMETHING LIKE HARMONIZE 70 SOMETHING PROCESSES ACROSS THE REGIONAL ENTITIES AND THAT TOOK A TREMENDOUS AMOUNT OF LEADERSHIP, TIME AND COMMITMENT FOR PEOPLE TO COME TOGETHER AND FIGURE OUT WHAT'S THE WAY TO DO THIS AS OPPOSE TO DEPENDING THE WAWHY DO IT IN MY REGION. SO I HAVE TO TAKE MY HATS OFF TO THE REGIONAL ENTITIES TO COME TO THE TABLE TO DEVELOP THE BEST PRACTICE WAY OF APPROACH THANKSGIVING IS ONCE WE GET THE TOOL IN PLACE AND ALL THE TRAINING ASSOCIATED WITH IT, THE REGISTERED ENTITY EXPERIENCE, PARTICULARLY ENTITIES LIKE NICK THAT TOUCH SEVERAL DIFFERENT REGIONAL ENTITIES WILL HAVE A MUCH MORE HARMONIOUS EXPERIENCE WITH THAT AND I KNOW I SAID BEFORE IF WE WERE STARTING FROM SCRATCH, WE MIGHT HAVE NERC INTKHRAOUD REGIONAL OFFICES, BUT WE ARE NOT STARTING FROM SCRATCH, WOO VERMEN INFECTED A WELL DEVELOPED HERITAGE OF A DIFFERENT SYSTEM AND I GUESS I KNOW TIM YOU'VE DONE A LOT OF WORK TO GETTING TO THAT CONSISTENT PLACE OR? I THINK REGIONAL STANDARDS SHOULD BE FEW. I AGAIN STANDARDS ARE FOR WELL KNOWN WIDE SPREAD RISKS AND THAT MEANS THAT IS TO BE COMMON ACROSS ALL THE REGIONS BUT THERE ARE SPECIAL CIRCUMSTANCES BUT I THINK REGIONAL STANDARDS HAVE THOSE IN PLACE. IN TERMS OF CONSIEVENCY IN THE CYBERSPACE BECAUSE THIS IS WHERE WE SEEM TO GET MOST OF THE TRACTION, I JUST THINK IT'S IMPORTANT TO RECOGNIZE WHAT WE DEAL WITH AS REGION CANS BE VERY UNIQUE, YOU NEVER KNOW WHAT YOU'RE GOING TO WALK INTO TODAY, AND ONE OF THE THINGS I CHALLENGE MY TEAM WITH IS TO BE OPEN MINDED ENOUGH TO UNDERSTAND DEPLOYMENT OF NEW TECHNOLOGIES. VIRTUALIZEATION AND THE CLOUD ARE NOT NEW TECHNOLOGIES BUT WE WILL HEAR ABOUT THIS LATER IF WE APLAY STRICT CONSTRUCTION TO APPROACH TO THAT, THE STANDARDS FOR BID THE USE OF THOSE TOOLS.

REGIONAL TO CYBER--DOES CYBER HAVE REGIONAL DIFFERENCES? ISN'T IT THE WORLD WIDE WEB?

REGIONAL COMPANIES WE WORK WITH. EACH ENTITY WE VISIT HAS DIFFERENCES AND HOW AND WITH WHERE THEY ARE IN THE CURVE AND HOW THEY DEPLOY IN TECHNOLOGY, AND VERY SIMILAR TO WHAT NICK SAID, WE TRY TO MAKE THE CONVERSATION ABOUT LIMITING THEIR SECURITY LIABILITY, NOT LIMITING THEIR COMPLIANCE LIABILITY BECAUSE IF THE ENTITIES I WORK WITH ARE FOCUSED ON LIMITING COMPLIANCE LIABILITY, WE'RE NOT GOING TO HAVE PROOF OF CONVERSATIONS AND THE LEVER WE USE THAT THAT COMMISSIONER IS I ASK THEM TO CONSIDER WHAT ARE THE RAMIFICATIONS OF A MAJOR SECURITY BREECH, REPUTATION, FINANCIAL HARM LOSS OF CUSTOMER INFORMATION VERSUS GETTING THE FINE FROM ME. SO I FIRMLY CONVINCED TO TACKLE THIS STUFF WE HAVE TO HAVE AN ALL HANDS ON DECK APPROACH AND WE HAVE TO LOOK AT THE REASONS IN NERC AND COMMISSION AS ALLIES IN IN FIGHT, IF WE'RE HIDING THINGS FROM ONE ANOTHER OR FOCUSED ON SOMETHING THAT HAPPENED FOUR YEARS AGO OR CHASING YESTERDAY'S PROBLEM, WE'RE NOT GOING TO BE ABLE TO TACKLE THIS PROBLEM. THREAT VECTORS, TECHNOLOGY, THE OPPORTUNITIES AND MOTIVATIONS CONSTANTLY CHANGE SO WE HAVE TO BE ON THE SAME TEAM. THAT MEANS WE'RE GOING TO BE INCONSISTENT SOMETIMES.

ANYONE ELSE?

FIRST I'M VERY IMPRESSED BY TIM'S REMARKS, BUT I THINK THAT YOU KNOW JUST SO MY REMARK WAS UNDERSTOOD IS THAT, YOU KNOW I THINK THAT REALLY APPA FAVORS NATIONAL STANDARDS WE DON'T WANT REGIONAL STANDARDS. I THINK IT WAS MORE OF THE IDEA THAT MANY PROBLEMS THAT SEEM TO HAVE BEEN MENTIONED IN THE CONTEXT OF CREATING THE STANDARD SEEMS LIKE IT'S MORE OF A KNEE JERK REACTION TO STANDARD CREATION AS OPPOSE TO LOOKING AT OTHER TOOLS THAT ARE IN THE TOOL BOX SUCH AS GUIDANCE AND THAT'S JUST IT, I THINK WE APPRECIATE SOME OF THE ELEMENTS THAT YOU KNOW NERC HAS EMBRACED WITH THOSE LINES WITH RESPECT TO GUIDANCE ON WINTERIZATION ASK THINGS LIKE THAT ARE A GOOD FIRST STEP RATHER THAN JUMPING TO A STANDARD. SO THAT WAS THE IDEA OF NOT TRYING TO NECESSARILY MOVE TOWARDS THAT KIND OF REGENERATION.

YEAH, I GUESS I FEEL LIKE IT'S A BIT OF CYCLIC IN THE BEGINNING IT WAS JUST STANDARD, STANDARD, STANDARD, YOU KNOW WE HAD HUNDREDS OF DIRECTIVES OUT TO NERC AND THEN AS THE STANDARDS MATURE AND WE STARTED THE PARAGRAPH, 81 OR WHATEVER THE PROCESS IS, STREAMLINED STANDARDS AND NOW THERE SEEMS TO BE SOMETIMES THE SLOWNESS IN TURNING TAKEN--THEY STANDARDS AS AN APPROACH FOR NEW ISSUES SO IT'S A BALANCE IN MY MIND AND THERE HAVE TO BE TIMED WHEN THERE'S A NEW STANDARD BECAUSE THERE'S A TUE CHALLENGE.

I WANT TO GO TO A DIFFERENT ISSUE BUT THAT ALSO KIND OF LIES THAT TRANSPARENCY VERSUS SECURITY, AND THAT'S AN ISSUE THAT'S GOTTEN A FAIR AMOUNT OF ATTENTION IN RECENT MONTHS WHICH IS THE QUESTIONS WE'VE BEEN GETTING TO DISCLOSE IDENTITIES OF PEOPLE WHO VIOLATE THE SIP STANDARD AS THE COMMISSION'S CURRENTLY PROCESSING, FOIA REQUESTS FOR THE IDENTITY OF EVERY SIP VIOLATORS SINCE THE MONTHLY FILINGS BEGAN IN 2010, AND WELL OVER 200 INDIVIDUALLY PROCESSED FOIA REQUESTS, THE APPROACH THAT NERC HAS TAKEN SINCE THE BEGINNING WHICH WAS TO FILE SIP VIOLATORS AS UNDISCLOSED REGISTERED ENTITY WAS LARGELY UNCHALLENGED FOR MANY YEARS AND UNEXAMINED AS FAR AS I KNOW BUT IT'S BEING SQUARELY ASKED ABOUT NOW. THIS SEEMS TO BE A RUMOR IN THE TWITTER VERSE THAT THIS WAS HAPPENING BEFORE I GOT HERE, BUT IT'S IN THE SPOTLIGHT RIGHT NOW. WE'VE NEVER REALLY HAD A PUBLIC PROCESS TO HAVE A DISCUSSION OR CONSIDERATION OF WHAT THE RIGHT BALANCE IS BETWEEN TRANSPARENCY, SO WE CAN LEARN FROM WHAT HAPPENED IN THE STATE REGULATORS AND OTHERS WHO FOLLOWED THIS HAVE AN INTEREST IN KNOWING WHAT'S HAPPENING BUT OF COURSE, PROTECTION OF GRID SECURITY AND HOW THE MONTHLY FILINGS OR HOW THE FILINGS ON PENALTIES MIGHT--WOO HAVE TO SCRUPULOUSLY AVOID CRITICAL INFRASTRUCTURE INFORMATION AND FOLLOW THE FAST ACT IN OUR OWN REGS BUT WE HAVE TO ARE CAREFUL WE'RE FOCUS ON THE OVERPROTECTING INFORMATION THAT MIGHT HAVE MORE REPUTATIONAL HARM HAN SECURITY HARM AND IT'S LEGITIMATE INTEREST IN TRANSPARENCY. SO I WOULD LIKE TO--I THINK THERE WOULD BE REAL VALUE IN HAVING SOME KIND OF PUBLIC PROCESS TO DISCUSS THIS AND I'M CURIOUS IN ANYONE ON THE PANEL WOULD LIKE TO COMMENT EITHEROT ISSUE WHICH SEEMS TO BE HOT RIGHT NOW OR HOW WE GET OUR HANDS AROUND IT. JENNIFER.

SO AS YOU KNOW THIS ISSUE IS VERY IMPORTANT TO EEI'S MEMBERS AND IN FACT TO ALL REGISTEREDDENNITYS. IT'S NOT A SECRET THAT THE INDUSTRY HAD ITS STRUGGLES IN THE EARLY DAYS OF THE SIP STANDARDS AND THAT MOST UTILITIES PROBABLY DO HAVE A SETTLEMENT AGREEMENT ON FILE WITH--AND PROECTOMYOSIN ITING CRITICAL INFORMATION THAT COULD BE USED BY INTELLIGENTA ADVERSARIES BACK IN THEIR WAY TO EXPLOITING VULNERABLE,.

ESPECIALLY IF IT'S NOT MITIGATED YET.

AND MOST OF THEM HAVE.

AND PROBABLY MOST OF THE THEM HAVE AND I DON'T DISAGREE ON THAT BUT SOME OF THE SETTLEMENT AGREEMENTS FILED EARLY ON CONTAIN A LOT OF INFORMATION ABOUT EXACTLY HOW THE ISSUES WERE MITIGATED AND SO IF YOU HAVE INFORMATION ABOUT HOW AN ISSUE WAS MITIGATED THEN HAVE YOU INFORMATION ON HOW A NEW VULNERABILITY MIGHT BE EXPLOITED SO THERE HAS TO BE A BALANCE. WE SUPPORT THE PROCESS THAT FERC HAS EMBARKED UPON NOW. IT'S TEDIOUS, WE RECOGNIZE THAT BUT WE THINK THE CASE BY CASE EXAMINATION OF THE PARTICULAR AGREEMENTS IN QUESTION ARE HELPFUL AND USEFUL AND I THANK YOUR STAFF BECAUSE I KNOW IT'S A LOT OF WORK.

ANYONE ELSE?

I WAS GOING TO MAKE AN OBSERVATION, THERE IS A LOT OF FROG AROUND THIS ISSUE RIGHT NOW WITH THE SOME OF THE RECENT NAME DISCLAYSURES AND I THINK IT'S APPROPRIATE AND I WOULD ENCOURAGE THE COMMISSION TO HAVE A THOUGHTFUL AND DELIBERATERATIVE PRACTICES CESS IN DETERMINING HO YOU IT WOULD LIKE TO PROCEED IN THIS AREA. I THINK IT'S IMPORTANT TO UNDERSTAND THE DIFFERENCES BETWEEN SIP VIOLATIONS MITIGATED OR NOT AND OMP VIOLATIONS ARE THE RESULT OF RANDOM EVENTS THAT OCCUR ON THE SYSTEM THAT WILL OR WON'T BE WELL PROTECTED AGAINST. IN THE SIP AREA WE'RE DEALING WITH DETERMINED ADVERSARIES IS IT WHILE WE HAVE A CORE PRINCIPLE IN OUR COUNTRY OF TRANSPARENCY AND DESIRE FOR THAT IS IT I THINK THAT'S VERY VALUABLE CHARACTERISTIC DEMOCRACY, AT THE SAME POINT IN TIME, WE DON'T WANT TO BE PLAYING OUT BLUEPRINTS FOR HOW ENTITIES CAN BE ATTACKED FOR SUCH A CRITICAL SECTOR. SO I THINK MITIGATED OR UNMITIGATED THERE'S A LOT OF SENSITIVITY AROUND THIS ISSUE AND I WOULD ABSOLUTELY ENCOURAGE THE COMMISSION TO HAVE THOUGHTFUL DELIBERATATIVE PROCESS AND A PUBLIC PROCESS AROUND HOW TO HANDLE THIS BECAUSE IT'S NOT A SIMPLE PROBLEM. SIMPLE ISSUE TO RESOLVE.

I AGREE WITH WHAT'S BEEN SAID, BUT WITH PERSONAL EXPERIENCE WHERE WORKING WITH INDUSTRY PARTNERS THAT HAVE HAD IN SIGNIFICANT VIOLATION EVEN AFTER THE MITIGATION HAS TAKEN PLACE, THERE'S STILL IN A RECOVERY PERIOD AND I STILL WORRY ABOUT THESE COMPANIES, THE WORK DOESN'T END FOR ME, WHEN YOU SIGN THE SETTLEMENT AGREEMENT, AND SIGN UP ON THE MITIGATION, IT'S SUSTAINABILITY ISSUE AND MY CONCERN WITH RELEASING THE NAMES TOO SOON, I DO SUPPORT TRANSPARENCY BY THE WAY, BUT RELEASING THE NAMES TOO SOON, IT'S SORT OF LIKE THERE'S A WEAKENED ANIMAL IN THE HEARD AND THAT'S WHERE ALL THE LIONS WILL GO. I THINK WE NEED TO EXTREMELY CAREFUL WITH THAT BECAUSE MITIGATION ITSELF THERE'S STILL A RECOVERY PERIOD ASSOCIATE WIDE IT BECAUSE A LOT OF THE ISSUES ARE NOT TECHNILOGICAL, THEY'RE CULTURAL ORGANIZATIONAL AND THERE ARE IS A TRICKLE DOWN AND FOLLOW ALONGS THERE.

I WILL BRIEFLY SAY, I AGREE THE ISSUE NEEDS MORE DISCUSSION.

THANK YOU VERY MUCH.

I JUST WANT TO PICK UP WITH COMMISSIONER LAFLEUR LEFT OFF. IT'S AN IMPORTANT ISSUE, IT'S NOT AN EASY ISSUE. IT'S COMPLICATED AS EVERYONE EVERYONE PHEPGZED, TRANSPARENCY IS AN IMPORTANT GOAL BUT I WANT TO TALK MORE ABOUT DETERRENCE BECAUSE ONE OF THE ISSUES IS WE WANT PEOPLE TO KNOW WHAT'S BEEN PENALIZED AND SO ON, AND MAYBE IF THERE'S NOT ANY ISSUES WITH REGARD TO SECURITY, BUT AT THE SAME TIME WE ALSO WANT TO DETER COMPANIES FROM NOT FOLLOWING OR WE WANT TO ENCOURAGE COMPANIES AND SEND COMPANIES TO FOLLOW SIP REQUIREMENTS AND SO ON. SO I--THIS GOES BACK TO FIRST YEAR LAW SCHOOL WHEN YOU LEARN ABOUT WHY PEOPLE GET PENALIZED OR WHY IN CRIMINAL LAW WHY PEOPLE GET SENT TO JAIL. SOMETIMES PEOPLE GET SENT TO JAIL BECAUSE OF JUSTICE SOMETIMES WE DO IT TO DETER FUTURE ACTION OR RECIDIVISM. SO MY CURRENT THOUGHTS IS THE COMPANIES THAT ARE PENALIZED BUT WE DON'T NAME NAMES BECAUSE THEY'RE NOT SUFFICIENTLY INSENTED NOT TO DISREGARD THE RULES OR SOMETIMES DISREGARD BUT SOMETIMES JUST NOT FOLLOW THE RULES SUFFICIENTLY UNTIL NEXT TIME SO I WANTED TO ASK MR. ROB, MAYBE IF YOU COULD--I KNOW IT'S A TOUGH ISSUE BUT AGAIN MAYBE THERE'S A WAY WE COULD DESIGN SOMETHING WHERE WE < THE COMPANIES THAT ARE PENALIZED BUT DON'T CONNECT THEM WITH THE ACTUAL ISSUES ASSOCIATE WIDE NOT FOLLOWING SIP REQUIREMENTS SO THAT PEOPLE DON'T KNOW THE ACTUAL SECURITY ISSUE?

I'M SURE THERE A PATH THROUGH THIS THAT PEOPLE CAN GET ALIGNED AROUND. MY VIEW IS THAT THE--I THINK IT NEEDS TO BE CLEAR AND TRANSAPPARENT SO THAT EVERYBODY UNDERSTANDS THE RULES AGAIN. THE ONE POINT I WOULD MAKE THOUGH IS THAT IS IMPORTANT AND IT BUILDS ON SOMETHING THAT KIM SAID THAT I THINK IS REALLY, REALLY IMPORTANT. WE CAN'T FINE A COMPANY ENOUGH RELATIVE TO THE RISK THAT THEY HAVE FROM A CYBER EVENT ISSUES RIGHT? AND I THINK MANAGEMENT AND EXECUTIVES UNDERSTAND THAT. THE ISSUE WOE HAVE TO MAKE SURE WE'RE DOING IN ALL OF OUR WORK AND IF ENFORCEMENT IS PART OF THE PUZZLE HERE IS THAT TOP MANAGEMENT HAS ATTENTION TO THE ISSUES IN PLAY. IF YOU GO BACK TO THE WORK THAT TIM AND A COUPLE OF THE OTHER REGIONS DID AROUND THE ROOT CAUSES OF MAJOR SIP VIOLATIONS, THE VAST MAJORITIES ARE NOT RELATED ISSUES ARE NOT RELATED TO HAVING THE WRONG WIDGET OR SOMETHING LIKE THAT, THEY'RE EMBEDDED IN MANAGEMENT STRUCTURE, APPROACH, PHILOSOPHY, ALL THAT KIND OF STUFF SO REALLY WHAT WE'RE DOING IS MAKING SURE THAT ALL OF OUR ACTIONS AROUND SIP COMPLIANCE, RIGHT IS ALL MIRRORED AROUND CHANGING MECHANICMENT BEHAVIOR AS OPPOSE TO PENNALLIZING, THE PEN AFFAIRS TEAM LEADER SEPART OF THAT BUT NOT THE ONLY PART SO THAT'S IMPORTANT TO KEEP IN MIND.

WOULD YOU AGREEN CELLS THAT PART OF THE INCENTIVE FOR SIP COMPLIANCE IS MANAGEMENT TO CALL AND INSURE THE PROPER APPROACHES THAT THE SIP REQUIREMENTS ARE COMMRI WITH IS THAT THEY DON'T WANT TO BE EMBARRASSED THAT THEY WERE FINED?

ABSOLUTELY. ABSOLUTELY.

OKAY, SWITCHING SUBJECTS, I WAS REALLY INTRIGUED MR. BROWN BY YOUR SUGGESTION ABOUT THE FUEL SUPPLY CHAIN AS PART OF THE BULK POWER SYSTEM, CURIOUS IF YOU HAD FURTHER THOUGHTS ABOUT HOW YOU MIGHT GO ABOUT DOING THAT.

IF YOU DON'T MIND, I WOULD LIKE TO COMMENT ON THAT LAST QUESTION.

OKAY.

I'VE WORK WIDE A NUMBER OF BOARDS IN MY CAREER. AND THE FOCUS OF EVERY ONE OF THOSE BOARDS ON AUDITS OF ANY KIND HAS BEEN EXTREMELY SHARP WHETHER IT'S A FINANCIAL AUDIT, A CONTROLS AUDIT, WHETHER IT'S A NERC AUDIT, I DON'T SEE ANYMORE FOCUS FROM MY PARTICULAR BOARD ON NERC COMPLIANCE BECAUSE OF THE THREAT OF THE PENALTY. I JUST DON'T. AND I THINK BOARDS THAT ARE PROPERLY STRUCTURED AND ARE PROPERTILY FUNCTIONING WOULD BE IN THAT SAME BOAT. I DON'T DISAGREE THAT PENALTIES AREN'T NECESSARY WITH BOARDS AREN'T THAT FOCUSED BUT TO ME THAT'S A SMALL PERCENTAGE OF OUR INDUSTRY THAT THAT APPLIES TO, NOT THE VAST MAJORITY. SO ON TO THE FUEL SUPPLY. I BEGAN PIE CAREER AS A PINING ENGINEER AND I FOCUSED ON FUEL AND THE LACK THEREOF FOR THE VARIOUS PLANTS IN OUR PART OF THE COUNTRY IT'S INTERESTING WITH RESPECT TO GAS BECAUSE UNLIKEOT EAST COAST AND WEST COAST OUR GAS PIPELINE SYSTEM IS A NETWORK, ALMOST. MANY OF OUR GAS PLANTS HAVE TWO AND SOMETIMES THREE DIFFERENT PIPELINE OPTIONS FOR APPLICATIONSERATION AND SO WE'VE BEEN BLESSED BY THAT FROM A RELIABILITY PERSPECTIVE BUT I STILL AM A FIRM BELIEVER THAT FUEL IS PART OF THE MIX. I MEAN THE PLANT'S USELESS WITHOUT FUEL. YOU CAN LOOK AT A FORCED OUTAGE RATE ALL DAY LONG BUT FUEL HAS TO BE CONSIDERED AS PART OF THAT IN MY VIEW.

ANYBODY ELSE HAVE THOUGHTS ON THAT?

YEAH, I THINK THE BUILD ON THIS POINT BECAUSE I'M ALSO A PLANNER, YOU START TO THINK FROM A DIFFERENT PERSPECTIVE, NOT JUST BUILDING TO A CAPACITY MARGIN WHICH LIKE NICK INDICATED, YOU HAVE INFINITE CAPACITY WITHOUT FULL, YOU RATHER GO THROUGH AN ENERGY PROBLEM, SOLVING ENERGY PROBLEMS, MAKING SURE HAVE YOU FUEL TO SERVE THE OPERATOR AND SERVE EFFICIENT ENMERGEY NEEDS AND THAT CAN TACK A SPECTRUM OF DIFFERENT SOLUTIONS INCLUDING RESPONSE, PIPELINES AND RESOURCE INTERMITTENT RESOURCES AND OPPORTUNITY, VARIABLE RESOURCES, BATTERY, STORAGE, WHATEVER, BUT YOU KNOW GET THE--CHANGE THE PARDIME SO WE'RE NOT THINKING ABOUT THE FOUR STYLE CALCULATION TO LOOK AT CAPACITY AND LOOK MORE AND MORE AT THE ENERGY.

YEAH, I WOULD LIKE TO COMMENT THAT NATURAL GAS IS A MARVELOUS FUEL BUT IT SERVES MANY MASTERS, IT'S AN IMPORTANT SOURCE OF ENERGY IN FEED STOCK FOR A NUMBER OF DIFFERENT INDUSTRIES AS WELL. THE SPACING MARKET AND POWER GENERATION AND NOT WITHSTANDING THE PRODUCING REGIONS AND NEWER PRODUCING REGION, THE GUEST NETWORK THERE WAS BUILT PRIMARILY FOR THE SPACE HEATING MARKET AND NOW THAT ALL THIS IS COMING ONLINE ALTHOUGH MUCH OF IT IS SERVED BY WELL HEAD TYPE PRODUCTION, SOME OF IT IS NOT AND IT'S STILL VULNERABLE TO A LEGACY SYSTEM OF PIPELINES AND IT NEEDS TO BE MORE INVESTMENT IN THAT SYSTEM IN ORDER TO ADEQUATELY SUPPLY THOSE UNITS BUT NONETHELESS IN THOSE ALONG WEATHER EVENTS THOSE SYSTEM WILL COME UNDER STRESS BECAUSE OF THE LACK OF EITHER ONSITE OR VIRTUAL STORAGE.

I WAS GOING TO ADD ONE OTHER POINT TO BUILD ON THIS, WE'RE TALKING SPECIFICALLY AROUND NATURAL GAS IN MANY WAYS, SHAPES AND FORMS AND ONE OF THE OTHER PARADIGMS WE HAVE TO GET BEYOND IS THAT THE GAS INDUSTRY THINKS OF ITS ON A VOLUNTEERS UMKC EATIC BASIS DO I HAVE ENOUGH BTUS TO SERVE THE NEEDS OF MY CUSTOMERS WHETHER IT'S POWER GENERATION OR CIRCUITING, WE LEARN WITH COMING OUT OF CALIFORNIA THE DUCT CURVE AND SOLAR RAMP OF RATES IN WE THINK ABOUT THIS IN THE WAY THE POWER DOES IN TERMS OF PEAK VERSUS AVERAGE BECAUSE CAN HAVE ALL THE BTUS YOU WANT BUT IF YOU DON'T VICTIM ENOUGH PRESSURE IN THE SYSTEM TO MEET THE DEMANDS THAT THE POWER PLANTS HAVE THEN IT'S NOT PARTICULARLY HELPFUL. SO THE WHOLE PLANNING PARADIGM AND INTEGRATION BECOMES ONE MORE ORDER MORE COMPLICATED. I WANT TO SWITCH TO MR. BALASH'S SUGGIEST ABOUT THE SUPPLY CHAIN AND THE VENDOR ACCESS PROCESS, SO MR. ROB, WE ISSUED [INDISCERNIBLE], SO WE HAVE SUPPLY CHAIN REQUIREMENTS FOR UTILITY TO COME UP WITH A PLAN TO FIGURE OUT HOW TO ADDRESS THE SUPPLY CHAIN CONCERNS BUT I WAS CURIOUS WHETHER YOU THOUGHT A BETTER CERTIFICATION PROGRAM WOULD BE HELPFUL?

I THINK WE'RE VERY SUPPORTIVE OF THAT CONCEPT. MARK DO YOU WANT TO TALK ABOUT--

YEAH, WE'VE BEEN ENCOURAGING ORGANIZATIONS TO WORK TOGETHER TO ESTABLISH SOME CERTIFICATION APPROACHES, FOR EXAMPLE NASBE DOES THAT FOR THE GAS INDUSTRY, THE NORTH AMERICAN TRANSMISSION FORM WHICH DEVELOPED A SET OF CRITERIA TO BE USED FOR THAT CERTIFICATION, SO THE CONVERSATION'S ONGOING AND WE THINK THAT WOULD BE A STRONG--VERY HELPFUL TO INDUSTRY ALONG WITH THE COURSE TO THE STANDARD CONTRACT PERHAPS NEEDED TO AND MAYBE MENTION SOMING ON THAT GEN IFER?

YEAH, I WILL MENTION EEI IS SUPPORTIVE OF THE DISCUSSIONS GOING ON FOR THIRD PARTY CERTIFICATION AND ACCREDITATION, WE WILL NEED THEM. I DON'T THINK IT'S AN EPATIENT PARADIGM TO HAVE--AN EFFICIENT PARADIGM TO HAVE ONE COMPANY AUDITING ALL THE VENDORS, THAT'S NOT SUSTAINABLE, ONE THING EEI HAS DONE, I WOULD BE REMISS IF I DIDN'T MENTION, WE HAVE DEVELOPED MODEL PROCUREMENT LANGUAGE FOR CONTRACTS FOR VENDORS OF CYBER SYSTEMS. THIS IS PUBLIC NOW, IT'S POSTED ON EEI'S WEBSITE AND THE IDEA IS TO SET A LEVEL OF EXPECTATIONS FOR VENDORS THAT ARE DOING BUSINESS IN THIS SPACE AND TO ALLOW ENTITIES THEN TO TAKE THAT LANGUAGE, YOU KNOW MOLD IT AS THEY NEED TO TO FIT THEIR SPECIFIC BUSINESS PRACTICES BUT TO PUT ALL THE VENDORS ON A COMMON GROUND AND TO LET THEM KNOW WHAT OUR EXPECTATIONS ARE AS AN INDUSTRY, AS A WHOLE AND NOT AS A SEPARATE COMPANY BY SEPARATE COMPANY.

HOW DO ALL KNOW, I MEAN THAT'S ONE OF THE PROBLEMS RIGHT, TO HAVE INFORMATION ABOUT THE VENDORS THEMSELVES, APPROPRIATE VENDORS, I KNOW SOME REPORTS IN THE PRESS TO NERC IS LOOKING AT CHINESE VENDORS ON CERTAIN EQUIPMENT AND WE HAVE TO GET PERMISSION FROM GOVERNMENT AND SO ON BUT IS IT POSSIBLE FOR THE PRIVATE SECTOR TO HAVE SUFFICIENT INFORMATION TO KNOW WHICH VENDORS ARE TRUSTWORTHY AND WHICH AREN'T?

IT'S A CHALLENGE AND A LOT OF THAT IS VENDORS WE ARE DEALING WITH, WE HAVE SOMETHING WHERE WE LOOK AT EVERY VENDOR BUT THAT'S NOT SUFFICIENT TO GIVE EVERY COMPANY, EVERY VENDOR, THIS IS AN AREA WHERE WE WILL NEED INCREASED COLLABORATION WITH THE FEDERAL GOVERNMENT, NO QUESTION ABOUT IT.

JUST JENNIFER THAT IS SO TRUE AND I THINK, YOU KNOW WE HEARD AS OF YESTERDAY THAT THE DOE IS MOVING IN THAT DIRECTION LOOKINGA THE THIS VERY PROBLEM. BUT I THINK IMPORTANTLY, YOU KNOW FROM JUST A PUBLIC POWER PERSPECTIVE AND ONE OTHER PIECE OF THIS IS THAT, YOU KNOW WE HAVE SMALLER COMPANIES, DEALING WITH A VARIETY OF VENDORS SO THAT'S ALL THE MORE REASON I THINK THAT WE WANT THAT PROGRAM IN PLACE WHERE WE'VE GOT SOME KIND OF CERTIFICATION, BUT I THINK ALSO TO THAT END IS THAT WEB CONNECTED DON'T WANT TO DRIVE VENDORS AWAY FROM OUR INDUSTRY WHICH IS I WOULD SAY FOR EXAMPLE SECURITY CONCERNS IN THE NUCLEAR INDUSTRY CAUSE THAT KIND OF RIPPLE EFFECT WHERE ALL OF A SUDDEN, YOU LOST VENDORS THAT WERE IMPORTANT TO PEOPLE AND I THINK WE'RE ALL CONCERNED ABOUT THE COST OF ELECTRICITY AND MEN AND WOMEN THE IMPACT WOULD BE THERE. SO THAT'S ONE OF THOSE OTHER PIECES.

TWO MORE SUBJECTS I WANTED TO TALK ABOUT. SEAMS I AND I KNOW WE HAVE A PANEL ON THIS AND WE HAVE A LOT OF EXPERTISE ON THIS PANEL AND THE CONCERN I HAVE IS THAT OBVIOUSLY MR. BALASH MENTIONED COLD WEATHER, POLEAR VORTEX THE LAST FEW YEARS AND I WANTED TO GET YOUR--MR. BROWN AND EVERYONE ELSE ON THE PANEL YOUR THOUGHTS ON WHAT WE CAN DO TO IMPROVE RELATIONSHIPS AND OPERATIONS BETWEEN REGIONS SO THAT IF IT'S REALLY COLD I CAN MISO AND STP ADDITIONAL POWER INTO MISO AND PREVENT OR REDUCE THE RISK OF HAVING OUTAGES.

SO COMMUNICATION, COMMUNICATION, COMMUNICATION. STATED ALMOST MY ENTIRE CAREER THAT MOST BUSINESS PROBLEMS ARE PEOPLE PROBLEMS AND MOST PEOPLE PROBLEMS ARE COMMUNICATION PROBLEMS. I'M PLEASED THAT THE LEVEL OF COMMUNICATION CONTINUES TO INCREASE. THE RELATIONSHIPS CONTINUE TO INCREASE AND THE CLARITY SURROUNDING THE OPERATING AGREEMENTS CONTINUES TO INCREASE. BUT THAT'S WHAT IT TAKES IN MY MIND, IT'S PURE AND SIMPLE, AND THE STRONGER THE RELATIONSHIPS ARE, THE BETTER THE COMMUNICATION'S GOING TO BE.

ANYBODY ELSE?

OKAY, WE WILL COVER IT MORE IN THE NEXT PANEL. LAST POINT, MR. BALASH, I WAS STRUCK BY LANGUAGE IN YOUR STATEMENT, AND YOU MENTION TODAY THIS MORNING, YOU SAID WE ENCOURAGE THE COMMISSION TO RECOGNIZE THE SPIRIT OF THE 2017 DOE NOER, AND IT WAS INTERESTING, I FOUND BECAUSE YOU KNOW THE COMMISSION VOTED FIVE-NOTHING TO REJECT THE DOE NOPER, AND WE DIDN'T BELIEVE THAT THERE WAS SUFFICIENT EVIDENCE TO SUPPORT WHAT THE DEPARTMENT OF ENERGY PROPOSED AND I NOTICE INNED ARTICLE RIGHT AFTER THAT, A FERC REJECTING THE DOE NOPER AND YOU WROTE A NOTE TO THE SECRETARY OF DEPARTMENT OF ENERGY SKPE BAKUGAN YOU WERE GOING TO WRITE A REPORT TO REBUT THAT AND THEN MEDDLE, YOUR LAB DID ISSUE A REPORT AND THEN PJM HAD SERIOUS CONCERNS ABOUT THE VALIDITY OF SOME OF THAT. MY AT SOME POINT WHERE IS THE EVIDENCE, WHERE'S THE RECORD, I THINK YOU SUGGESTED EVIDENT OF THE RECORD, YOU SUGGEST THAD REALLY, INSTEAD OF TALKING ABOUT RELIABILITY, TALK ABOUT PRICE, YOU SAID PRICE WOULD INCREASE IF WE WERE TO BECOME TOO RELIANT ON NATURAL GAS, AND LESS RELIANT ON COAL AND NUCLEAR, BUT WHERE'S THE EVIDENCE ON RELIABILITY BECAUSE I'M STILL WAITING TO SEE IT AND I HAVEN'T SEEN A LOT OF IT PRESENTED TO THE COMMISSION YET.

WELL, I DON'T KNOW WHAT'S BEEN PRESENTED TO THE COMMISSION BUT THIS COMMENT THAT WITH RESPECT TO PJM, WE'VE HAD A LONG CONVERSATION OVER THE PAST FEW MONTHS BUT I AM AN ECONOMIST SO I VIEW HIGH PRICES AS AN INDICATION OF SCARCITY. SO THEREFORE, AND EASTERN PJM DURING THE [INDISCERNIBLE] CYCLONE WHEN PRICES REACHED $96 PER MILLION BTU AND THE [INDISCERNIBLE], AND GATEWAY NEW YORK WHEN PRICES REACHED $146 MILLION BTU AND WHEN THE HUB WAS OVER A HUNDRED DOLLARS BTU, THAT IS THE INDICATION THAT THE NATURAL GAS IS [INDISCERNIBLE]. I THINK THAT THE DEGREE TO WHICH THE NEW ENGLAND GENERATORS WERE NEARLY OUT OF OIL AND UNABLE TO RECEIVE NATURAL GAS THAT THEY HAD TO RELY ON EMERGENCY SHIPMENTS OF RUSSIAN LIQUEFIED NATURAL GAS IS AN INDICATION THAT THE GAS SUPPLY INFRASTRUCTURE IS NOT SUFFICIENT TO RELIABLE SUPPLY THE ELECTRIC POWER GENERATION SECTOR. THAT'S NOT SAYING THAT THERE'S NOT PLENTY OF NATURAL GAS, AS WE KNOW NATURAL GAS COSTS THREE DOLLARS OR LESS IN PENNSYLVANIA WHERE I AM STATIONED. THERE'S PLENTY OF NATURAL GAS, IT'S WHETHER YOU CAN GET IT AROUND BECAUSE AS I MENTIONED EARLIER IT SERVES A NUMBER OF MASTERS, THAT IS IT HAS A NUMBER OF USES, HIGH VALUE USES IN THE ECONOMY. IT HAS A LOT OF TAKERS. AS A RESULT THESE KIND OF EVENTS HAPPEN MAYBE ONCE A YEAR, MAYBE ONE EVERY OTHER YEAR. THE STRESS TO THE SYSTEM ISN'T GOING TO BE THERE MOST OF THE YEAR ISSUES MOST THE YEAR THE PIPELINE IS FINE, IT'S JUST IN THESE EVENTS AND WHO WANTS TO PAY FOR THE NEEDED CAPACITY? WHO WANTS TO PAY FOR THE ONSITE FUEL STORAGE? JUST FOR THOSE KINDS OF EVENTS? THAT'S WHAT WE'RE DRIVING AT? SO IN THE NEW ENGLAND SITUATION IF WE WERE TO BUILD MORE PIPELINE CAPACITY INTO NEW ENGLAND WE WOULDN'T NECESSARILY NEED MORE COAL OR NUCLEAR.

NO, BUT TO THE EXTENT THAT YOU RETIRE COAL AND NUCLEAR YOU INCREASE THE STRESS ON THE NATURAL GAS.

AND WITH REGARD TO THE OPERATION OF COAL AND NUCLEAR DURING COLD WEATHER EVENTS, YOU INDICATED AND THERE WERE ISSUES WITH THE WIND, THE WIND FORECAST THAT WIND BETWEEN JANUARY 20-30, 2018 WE REFERENCED THERE WAS DROP OFF IN WIND AND I KNOW IN YOUR TESTIMONY, YOU SAID YOU TALKED ABOUT THE RELIABILITY OF COAL AND NUCLEAR PLANT WASN'T A FACT THAT A LOT OF COAL AND NUCLEAR PLANTS CAPACITY GOT SHUT DOWN BECAUSE OF THE COLD WEATHER IMPACT. FOR EXAMPLE COUPLE NUCLEAR PLANTS WENT DOWN.

YES THERE WERE ICE ISSUES ON THE NUCLEAR PLANT, IN THE WIND, I WAS REFERRING TO 2019.

YOU WERE TALK ABOUT THE MISO?

YES, SIR. , OKAY. THANK YOU.

I WANT TO CONTINUE A LITTLE BIT WITH THE RELIABILITY ISSUE, I WANT TO START WITH MARK. YOU MADE AN INTERESTING COMMENT ABOUT THE ISSUE OF CAPACITY VERSUS AN ENERGY PROBLEM THAT GOES IN TERMS OF RESERVE MARGINS. AS LONG AS I'VE BEEN PRACTICING WE TALK ABOUT RESERVE MARGINS AND WHAT I WANT TO KNOW IS THE WAY THAT YOU LOOK AT MARGINS CHANGED OVER TIME TO RECOGNIZE THAT THE TYPE OF RESOURCES WE HAVE, CAPACITY RESOURCES OPERATE DIFFERENTLY AND WE HAVE THE INTERMITTENT RESOURCES AND WE THEN TALK ABOUT THAT YOU MIGHT NOT HAVE THE GAP BECAUSE YOU CAN'T GET FROM CAPACITY OR TOO MUCH USAGE, DO WE--HAS THE WAY WE LOOK AT RESERVE MARGINS IN THE RTOS HAS IT CHANGED OVER TIME TO ACCOMMODATE THE WAY IN THE SYSTEM IS ACTUALLY OPERATING AND IF NOT, WHAT SHOULD WE IN THE RTOS BE THINKING ABOUT ABOUT RESEARCH MARGINS.

I WOULD SAY THAT YOU KNOW MANY OF THE RTOS AND ISOS RECOGNIZE THE ISSUE AND HAVE BEEN ADDRESSING IT IN A MULTIFACETED WAY. I THINK THAT THERE ARE BASIC ASSUMPTIONS ONE USES WHEN ONE STARTS LOOKING AT THE ONE EVENT IN TEN YEARS, BASED ON FORCED OUTAGE RATES THAT TO INSURE YOU HAVE SUFFICIENT CAPACITY, SOME OF THOSE ASSUMPTIONS COME INTO QUESTION. AND THAT'S WHO I NEED TO START TRANSITIONING IS BUILDING THE TOOLS NEEDED MAKING SURE EVERYBODY HAS THOSE TOOLS TO ACTUALLY ANSWER THE ENERGY CHALLENGE RATHER THAN JUST FOCUSING ON CAPACITY. BECAUSE, THE CAPACITY WILL NOT GET YOU THERE ANYMORE. CERTAINLY AN IMPORTANT PARAMETER, ONE OF THOSE, YOU HAVE TO HAVE CAPACITY, DON'T GET ME WRONG BUT YOU HAVE TO HAVE SUFFICIENT ENERGY OR ABILITY TO CREATE ENERGY WHEN YOU NEED IT AND MAKE SURE IT'S THERE TO SERVE THE CONSUMER.

THAT SEEMS CONSISTENT, I WAS FORTUNATE THROUGH THE CALIFORNIA ISO WHEN WE ARE MADE THE INFORMATION THAT THEY'RE NO LONGER AT JUST LOOKING AT PEAK CAPACITY, BUT NOT PEAK CAPACITY BECAUSE OF THE [INDISCERNIBLE], AND IT'S NOT TRAILING OFF AT 5:00, THEY SIMPLY STILL NEED MOIRE AND I THINK THAT GOES TO--POWER, THAT GOES TO WHAT THE REGIONAL ISSUES THAT WHAT CALIFORNIA IS DEALING WITH, MAYBE DIFFERENT THAN WHAT PGM IS DEALING WITH AND NEW ENGLAND IS DEALING WITH, AND IS THERE A WAY THAT DIFFERENT UTILITIES AND RTOS DOING THINGS DEFICIENT DIFFERENTLY? NOT A ONE-SIZE-FITS-ALL STANDARD, I DON'T THINK THAT WILL WORK BUT ADDRESSING THOSE ISSUES AND THINKING ABOUT THE CAPACITIES ARE NOT HAVING THEM LOOK AT THE WRONG STANDARDS, WHEN WE ALWAYS TALK ABOUT RESERVE MARGINS, YOU KNOW WE'RE AT 16% OR MAYBE THEY'RE NOT ENOUGH, BUT IS THAT REALLY THE RIGHT STANDARD THAT EVERYBODY SHOULD BE LOOKING AT?

WELL, I GUESS AS FAR AS FROM OUR PERSPECTIVE, WE CONTINUE OF COURSE--WE LOOK FORWARD ON PERFORMANCE AND LOOK FORWARD IS SEE WHAT'S HAPPENING ON THE SYSTEM AND WE SEE FOLKS THAT ARE GETTING LOW ON CAPACITY THAT'S STILL AN ISSUE, OKAY? BECAUSE YOU DON'T HAVE THE FLEXIBILITY YOU HAD IN THE SYSTEM YOU HAD BEFORE. WHEN YOU HAVE UNITS GET FORCED OUT AND HAVE YOU WEATHER UNEXPECTED THAT'S AN ISSUE BUT ALSO DON'T FORGET ABOUT AND MAKE SURE YOU LOOK AT ENERGY AND CONTINGENCIES THAT MIGHT GET YOU INTO THOSE ISSUES AS WELL, COLD WEATHER, CUTS IN PIPELINE, WHAT ARE THE RAMIFICATIONS OF THOSE ON YOUR SYSTEM AND WHO YOU WILL YOU THEN MAKE SURE HAVE YOU SUFFICIENT ENERGY ON THE SYSTEM DURING THOSE TIME PERIODS AS WELL. RIGHT. BUT THAT GETS TO ONE OF MY CONCERNS ARE WE TREATING ALL CAPACITY THE SAME OR SOME CAPACITY DIFFERENT THAN OTHER? IT'S OKAY IF YOU KNOW YOU CAN CATCH IT TOMORROW BECAUSE YOU KNOW THAT WIND'S GOING TO BE AVAILABLE OR THE SUN BUT IF WE HAVE LIKE WE HAD THIS PAST WINTER WHERE BECAUSE OF THE APPLICATIONSERATION OF CHARACTERISTICS THE WIND RESOURCES COULDN'T BE USED BUT MAKE YOU FIX THE COMPONENT BUT WITH CALIFORNIA DO THEY HAVE THE RIGHT SORT OF CAPACITY. NOT SAYING THEY DON'T BUT SAYING THEY'RE LANGUAGING ABOUT THOSE ISSUES AND WE NEED TO BE MAKING SURE THAT PEOPLE ARE THINK BEING DO THEY HAVE THE RIGHT TYPE OF CAPACITY?

RIGHT TYPE OF CAPACITY OR SOURCES SO THAT IN THE END WHEN YOU HAVE CERTAIN REQUIREMENTS IF ARE ENERGY HAVE THE RIGHT MIX TO GET TO THAT ENERGY.

MR. GALLAGHER, YOU MENTIONED EARLIER THAT WE WERE NOT ADDRESSING CERTAIN REGIONAL ISSUES, THAT WAS IN YOUR TESTIMONY, DO YOU HAVE EXAMPLES OF THOSE WHERE YOU THINK THAT WE'RE NOT ADDRESSINGA PROPER REGIONAL ISSUES AND WE SHOULD BE DOING SOMETHING DIFFERENT?

I'M NOT IF AM WITH WHAT YOU'RE SAYING, COMMISSIONER?

UNFORTUNATELY IN RIGHTING DOWN MY NOTES I RECALL YOU SAYING CERTAIN TIMES WHEN WE'RE NOT ADDRESSING REGIONAL ISSUES BECAUSE WE'RE FOCUSING ON NATIONAL ISSUES AND I KNOW YOU SUPPORT A NATIONAL AN STARRED--STANDARDS BUT DO YOU KNOW OF ISSUES FOR REGIONAL?

THE COMMENT I WAS MAKING WAS TERMS OF CONSISTENCY WHICH WAS A CHALLENGE, IT'S NOT A QUESTION OF STANDARD BEING NATIONAL OR LOCAL, BUT THE SITUATION WE WALK INTO THAT EACH COMPANY WE WORK WITH CAN BE VERY DIFFERENT SO IT'S ALMOST A MICROCOMP OF THAT WHOLE PROBLEM, SO IF REQUIRES FLEXIBILITY, REQUIRES MY STAFF AND STAFF OF ALL THE REGIONS KEEP THEIR CREDENTIALS UP SO THAT'S A REAL CHALLENGE FOR US AND SO IF IF YOU'RE NOT CLEAR AND REQUIRES BEING ADAPTABLE AND IT REQUIRE RADIOS A GOOD PARTNER SHOULD WITH THE ENTITIES WE'RE WORKING WITH SO WE TRY TO BE PROACTIVE WITH THAT AND WE HAVE AN ACTIVE ASSIST PROGRAM, BUT WE WILL WORK WITH ENTITIES EVEN BEFORE THEY MAKE THE INVESTMENT, IF THAT'S USEFUL TO THEM, WE WILL TRY TO WORK WITH THEM TO FIND A WATHAT IS SECURE AND COMPLIANT. SO I APOLOGIZE IF I COB FUSED WITH MY EARLIER COMMENT. I DON'T BELIEVE THERE'S ANYTHING WE'RE NOT PAYING ATTENTION TO OR THE DEBATE ABOUT NATIONAL VERSUS LOCAL IS HARMFUL IT'S JUST TO CONSISTENCY WILL BE SOMETHING WE'RE CHASING IN THE SIP WORLD AND I WANT IT TO THE PROPER CONTEXT.

--THAT WE NEED NEW APPROACHES TO ADDRESS RISK?

THE CONTEXT OF THAT WAS THAT SAYING JUST A STAND WAS MAY NOT BE TIMELY ENOUGH TO ADDRESS NOW RISKS SOPHISTICATEDY WE WERE THE MANY OF THESTS THAT NERC AND THE REGIONS ARE INVOLVED WITH RIGHT NOW, THE EMP TASK FORCE IS A GOOD EXAMPLE ISSUES THE *EURPT MITTENT RESOURCE TASK FORCE IS A GOOD EXAMPLE WHERE WE'RE ABLE TO QUICKLY GET TASK FORCES TOGETHER TO LOOK AT THESE NEW RISKS AS THEY'RE CHANGING QUICKLY BECAUSE THE PACE OF CHANGE HAS INCREASED. I STARTED AS A YOUNG ENGINEER, YOU KNOW, WE WERE ALL INTEGRATED US AND THINGS WERE STABLE FOR QUITE A LONG TIME, THINGS HAVE CHANGED WHITE A BIT SINCE THAT TIME. MARK AND I ARE CO CHAIRING A SUBCOMMITTEE NOW TO LOOK AT HOW WE STRUCTURE OUR COMMITTEES SO WE'RE ABLE AND NIMBLE TO ADDRESS THESE ISSUES ON A NONSILOD QUICK WAY SO THAT WE CAN QUICKLY PUT TOGETHER A WORKING GROUP OR TASK FORCE IF THE NEED ARISES AND THAT'S WHAT I MEANT BY THAT COMMENT.

VERY HELPFUL, THANK YOU.

WE HAVE ABOUT 15 MINUTES LEFT ON THE PANEL SO I THINK AT THIS TIME, UNLESS MY COLLEAGUES HAVE ANY URGT IFER FOLLOW UP I WAS GOING TO TURN IT OVER TO STAFF TO SEE IF STAFF WANTED TO ENGAGE THE PANELS?

SURE, THANK YOU VERY MUCH. I HAVE A QUESTION ABOUT THE ANNUAL STATE OF THE RELIABILITY REPORT AND ACTUALLY A COUPLE QUESTIONS WEALATED TO THAT AND I RECOGNIZE THAT THERE'S CHANGING RESOURCE AND I GUESS THE QUESTION, THE FIRST PART OF THE QUESTION IS WHAT CHANGES TO NERC, THE REGIONS PLAN ON DOING WITH THE ANALYSIS OF THE ASSOCIATED REPORT AND THIS TIES WITH THE QUESTIONS WHEN THE COMMISSION E-PRESCRIBINGS HAVE ASKED US, WELL, DO YOU ENVISION CHANGES IN THE METRICS YOU'RE USING TO REPORT TO ACTUALLY GAUGE THE RELIABILITY OF THE ELECTRIC SYSTEM GOING FORWARD AS WELL?

YEAH, I THINK SO GOOD QUESTION, AND AS WE LOOK FORWARD, I WILL LOOK AT TWO TIME FRAMES, ONE FOR EXAMPLE WERE TO LOOK AHEAD FOR LONG-TERM RELIABILITY ASSESSMENT. WE'VE BEEN DOING A NUMBER OF THINGS THAT NERC TO IMPROVE OUR ABILITY TO SEA WHAT'S HAPPENING BASED ON THE CHANGES AND THE RESOURCES, FREQUENCY RESPONSE, LOOKING OUT FIVE-TEN YEARS BASED ON THE MIX OF INFORMATION WE GET AND WHAT DOES THAT LOOK LIKE, PROBABLISTIC ASSESSMENT SO GETTING MORE STOIKASTIC MODEL CASTIC AND ADDRESSING ENERGY ISSUES AND CHALLENGES THERE, SO WE'RE LOOKING AT THOSE KINDS OF AUGMENTATIONS TO THE LTRA SO WE CAN GET A BETTER VIEW OF WHAT REALLY THE RISKS LOOK LIKE BASED ON THE CHANGING RESOURCES. NOW FOR AN ONGOING BASIS WE GATHER INFORMATION WITH OUR ADD SYSTEMS AND WE HAVE BEEN IMPROVING THOSE AS WELL AS YOU PROBABLY KNOW, WE'VE ADDED WIND COLLECTION, NOW SOLAR INFORMATION COLLECTION SO WE'RE CONTINUING TO GATHER, EVEN LOOKING AT BATTERIES DOWN THE ROAD, GATHERING MORE INFORMATION ABOUT THEIR PERFORMANCE BECAUSE THAT FEE TO LOOK ACROSS THE SYSTEM, HISTORICAL PERFORMANCE IS NO GUARANTEE,IADY-YADDA, AND TECH TPHOLGZ DOES CHANGE BECAUSE HAVE YOU AN IDEA OF WHAT THE--HOW TO ISSUE THE STOIKASTIC MODELASTIC NATURE OF THESE, AND WE ARE LOOKING AT WILL THE BIG DEAL AND WHAT THE TOOL INDUSTRY WILL NEED TO MAKE SURE THEY CAN ADDRESS THESE RELIABILITY ISSUES AND HOW WE GET THOSE TOOL IN THE HANDS OF INDUSTRY, WHAT'S THE BEST WAY TO PULL THOSE COLLABORATIONS TOGETHER. SO I THINK THATIA KIND OF LIKE THE BIG ONES THAT WE ARE FOCUSED ON.

JUST A FOLLOW UP QUESTION, THIS IS TYPICALLY WHEN WE DO THE WINTER ASSESSMENTS AND SUMMER ASSESSMENTS AND NERC WILL SET THE CAPACITY LEVELS AND THERE A LOT OF TALK TODAY ABOUT LOOKING AT ENERGY AND THE FUEL RESOURCES AND HOW MANY MEGAWATT HOURS OF ENYERGY WE CAN SUPPLY OVER A PERIOD OF TIME BASED ON DIFFERENT RESOURCE MIXES WITH THE CHANGING RESOURCE MIX OF THE GENERATION FLEET THAT'S TAKING PLACE, DO YOU PLAN ON ANY CHANGES TO THE RELIABILITY ARK CESSMENT TO DIG INTO THAT MORE AND ACTUALLY PUT SPECIFIC METRICS IN PLACE TO MEASURE THAT?

YES.

DO HAVE YOU ANY MORE DETAILS IN TERMS OF--[LAUGHTER]

OF COURSE, I DIDN'T KNOW WHAT COLLABORATIVE ORGANIZATION WE'RE WORKING WITH, REGIONAL, NATIONAL AND INDUSTRY TO IDENTIFY WHAT DOES THE METRIC LOOK LIKE AND WHAT DOES THE DATA LOOK LIKE SO WE CAN PULL IT TOGETHER AND GO FORWARD, WE'RE LOOKING FOR HOURLY INFORMATION AND YOU KNOW WHAT KIND OF METRICS WOULD MAKE SENSE TO MEASURE ENERGY IN A FORWARD LOOKING BASIS, IT WILL BE A STOIKASTIC MODELASTIC PROCESS, AND I WAS GOING TO MAKE THE POINT THAT WE HAVE THREE REALLY INTERESTING HOT SPOTS IN THE COUNTRY RIGHT NOW THAT ARE CHALLENGING MOST EVERYTHING THAT EVERYBODY IN THIS ROOM THINKS ABOUT HOW AN ELECTRIC SYSTEM SHOULD BE DESIGNED AND OPERATED. CALIFORNIA, RIGHT VERY DIFFERENT RESOURCE, HIGHLY DEPENDENT ON SOLAR, NATURAL GAS, RETIRING BASE LOAD GENERATION SO WE HAVE A LABBATORY THERE INTO THE ISSUE SURROUNDING THAT TRANSITION. IN TEXAS, YOU KNOW WE'RE LOOKING AT RESERVE MARGINS THAT ANYONE OF US WOULD SCRATCH OUR HEAD AND SAY NO WAY IN HELL THEY CAN KEEP THE LIGHTS ON AND YET THEY DO THROUGH THE WAY THE MARKET WORKS AND GENERATION PERFORMANCE AND EVEN THROW A SCORCHINGLY HOT SUMMER LAST YORE SO THERE'S SOMETHING IN THE SOUP THAT THERE CHALLENGES HOW WE THINK ABOUT THINGS AND THEN GORDON UP IN NEW ENGLAND FINDS AGO ANOTHER RABBIT TO PULL OUT OF HIS HAT TO KEEP THE LIGHTS ON WHEN ANY OF US WOULD LOOK AT THE SITUATION AND SAY IT'S GOING TO BREAK. SO IN ADDITION, JUST CONTINUOUS IMPROVEMENT AROUND THE REPORT, ONE TECHNOLOGY TRANSFER I WOULD LIKE TO SEE US DO IS DISSECT THESE THREE LAB RAARE TOYS AND UNDERSTAND WHAT'S REALLY GOING ON THERE, THAT COULD CHALLENGE THE RULES OF THUMB THAT WE CARRY AROUND IN OUR HEAD, 15% RESERVE MARGIN AND THIS THAT AND SO FORTH. BECAUSE IT'S DIFFERENT, RIGHT? AND THE INNOVATION OCCUR IN THE MARKETS IN THESE MARKET AREAS PREDOMINANTLY BECAUSE THESE ISSUES ARE EPICENTERED, THERE'S REALLY UNDERSTANDING THERE THAT I DON'T THINK WE BAKED INTO ALL OF OUR THINKING AROUND RELIABILITY AND I THINK THERE--THIS WILL BE A LEARNING CURVE FOR US FOR A PERIOD OF TIME. AND WE'RE KIND OF COMMITTED TO STAY ON TOP OF THAT.

ANYBODY ELSE HAVE A RESPONSE TO THAT QUESTION.

IT'S A GREAT QUESTION ANDY AND I THINK THERE'S A REAL DANGER IS TRYING TO APPLY WHAT WE USE TODAY, IN THE COURSE OF OUR CAREERS TO ACKNOWLEDGE THE SYSTEM CHANGING AROUND US. LOOK NO FURTHER THAN RESILIENCE, WHEN YOU AND I WERE DOING STUFF WE HAD TO BE REZIPIENT AGAINST WEATHER, STORMS HIGH LOAD, EQUIPMENT FAILURE WE DIDN'T HAVE TO BE RESILIENT AGAINST INTENTIONAL MULTIVECTOR ATTACK OPEN SOURCE SOFTWAREY THINGS ARE CHANGING AROUND US. WE HAVE TO LOOK FOR THE METRICS BE OPEN MINDED AND INNOVATE AND I HAVE NONAPOPTOTIC THE FALL BECOME TO WHAT WE DO, WE CAN'T LOAD EVERYTHING AND THE GAME CHANGED CAN AND THIS IS A GREAT QUESTION AND IT'S SOMETHING WE HAVE TO WORK COLLECTIVELY ON. I.

I WOULD AGREE WITH WHAT WAS SAID BUT ONE OTHER PIECE THAT OCCURS TO ME IS THAT IN A SENSE, NERC DATA COLLECTION IS SOMEWHAT IN ITS INFANCY. I WOULD SUGGEST IN WHAT GOES WITH THAT, I THINK A BASEBALL STATISTICS AND OTHER THINGS, NOW THAT PEOPLE LOOK AT THAT YOU KNOW FOR YEARS THEY MISS AND WHAT REALLY CHANGED THAT WAS THE FACT THAT YOU KNOW THERE WAS ONE GENTLEMAN THAT CAME IN AND STARTED TO COMMUNICATE WELL ABOUT THE NUMBERS AS OPPOSE TO JUST FOCUSING ON THEM IN A SILOED MANNER AND IT PLAYS OFF OF WHAT NICK SAID AS A COMMUNICATION IS AN IMPORTANT PIECE AND I GUESS I WOULD JUST PROBABLY SUGGEST IT'S NOT AS IF I'M THROWING THAT BURDEN TO NERC BUT IT'S THE BURDEN FOR INDUSTRY, YOU KNOW AS WELL AS THE COMMISSION TO CONSIDER, I THINK WITH THAT, AS WE GO ALONG AND THE OTHER PIECE OF THAT IS THAT I THOUGHT I HEARD SOME REAL BEST PRACTICES COMING OUT OF JIM WITH RESPECT TO TEXAS AND OTHER REGIONS AND YET THEY MIGHT BE MARKET BEST PRACTICES BECAUSE OF THAT DIVISION OF RELIABILITY AND MARKETS THAT I HOPE THAT THOSE DON'T GET LOST AND ARE NOT COMMUNICATED TO PEOPLE IF INDEED THOSE ARE THINGS THAT OTHER PARTS OF THE COUNTRY COULD BENEFIT FROM.

OKAY, THANK YOU. DAVID?

I'M SORRY.

JUST QUICKLY I THINK THE CONCEPT OF [INDISCERNIBLE] NEEDS MORE INVESTIGATION. AND NOT NECESSARILY, IT WON'T CO INSIDE NECESSARILY WITH THE PEAK, WHETHER IT'S A DAY OR A WEEK AND A YEAR OR A MONTH IN A YEAR BECAUSE THAT BEARS FURTHER EXAMINATION BECAUSE THAT MAKES ONE CONCENTRATE ON WHAT RESOURCES ARE THERE READY TO SERVE THE SYSTEM AT THAT TIME.

THANK YOU. DAVID?

I HAVE TWO QUESTIONS, ONE ABOUT THE EI STATUS AND ANOTHER ABOUT THE THRESHOLD AND CRITERIA WITH RESPECT TO CREATING STANDARDS. FIRST REGARDING EI STAT, WITHIN THE BUDGET AND/OR THE PAST FEW YEARS AND CONSISTENT WITH THE STRATEGIC PLAN THAT EI SACK HAS PUT TOGETHER SIGNIFICANT INVESTMENTS PUT INTO THAT ORGANIZATION AND JIM YOU HIGHLIGHTED THE MUTATIONS YOU MADE INCLUDING ALL POINTS BULLETIN AND SIMILAR ACTIVITIES, I DON'T INTEND ANY CRITIQUE BUT I THINK ONE THING WOULD BE HELPFUL TO ILLUMINATE FOR A LOT OF US WHO DON'T GET INSIGHT INTO THE DAT TO DAY WORKINGS OF THE EI SAC AS MUCH AS WE PLIGHT INTO INTO THE OTHER ASPECTS OF NERC IS TELL US ABOUT HOW THE EI SAC TAKES THAT INFORMATION, ANALYZES IT AND DISTEMINATES IT IN PARTICULAR WITH OUR AGENCIES AND MEMBERS AND ALSO I WOULD LIKE LIKE MISS STERLING'S INSIGHT INTO HOW YOUR MEMBERS ENGAGE WITH THE EI SACK AND DERIVE VALUE FROM THE WORK IT'S DONE.

AND I HAVE ALL OF FIVE MINUTES TO RESPOND TO THAT.

[LAUGHTER]

I HAVE ONE MORE QUESTION. TOO. [LAUGHTER]

I WILL GIVE YOU A SNAPSHOT, YOU SHOULD COME OVER AND SPEND TIME WITH US AT THE EISAC AND THE STAFF, AND COMMISSIONERS AND OTHERS HAVE AND YOU WILL GET A BETTER SENSE FOR THE DAY-TO-DAY THERE ISSUES BUT THE IMPORTANT THING FOR THE EISAC, THE RELATIONSHIP OF THE GOVERNMENT PARTNER SYSTEM ABSOLUTELY CRITICAL BECAUSE THEY HOLD THE INTELLIGENCE THAT THAT WE USE TO HELP INFORM THE ACTIVITIES THAT WE GET OUT TO INDUSTRY. SO IT'S IMPORTANT FOR THAT ORGANIZATION TO HAVE STRONG TEST RELATIONSHIPS WITH DOE OR DHS AND YOU GO INCREASINGLY TO THE DEPARTMENT OF DEFENSE. AND SO WE FOCUS A LOT THAT THAT RELATIONSHIP, THAT SERIES OF RELATIONSHIPS, SOPHISTICATED THAT WE'RE IN THE INFORMATION FLOW AROUND, YOU KNOW THREATS AS THEY EVOLVE AND BECOME UNDERSTOOD. YOU KNOW ONE OF THE PREMIER PROGRAMS WE OPERATE ON BEHALF OF INDUSTRY IS THIS PRACTICAL WE CALL CRISP WHICH IS A PASSIVE MONITORING ENTERPRISE SYSTEMS FOR I DON'T KNOW HOW MANY MEMBERS WE HAVE IN THE PROGRAM, BUT IT COVERS ABOUT 75, 80% OF THE METERS IN THE U.S., AND ALLOWS US TO IN CONCERT WITH DOE, AND THE NA-GZAL LABS UNDERSTAND INBOUND, OUTBOUND INTERNET TRAFFIC AND YOU KNOW SOPHISTICATEDY WE CAN FIND--THERE'S UNTOWARD OR UNINTENDED COMMUNICATIONS WITH CHINA, WITH RUSSIA, WITH THE NETHERLANDS WHICH TURNS OUT TO BE AN INTERESTING PLACE FOR A LOT OF PEOPLE BECAUSE THE INTERNET LAWS ALLOW PEOPLE TO COME THROUGH THAT ANGLE. AND THE EISAC HAS DEVELOPED AN PHAEURBGSZING STATISTIC, THEY CAN TAKE CLASSIFIED INFORMATION, DECLASSIFY IT AND GET IT OUT TO THE INDUSTRY IN 24 HOURS ATHAT'S AN AMAZING ACCOMPLISHMENT. SO THAT'S AN EXAMPLE OF WHAT THEY DO AND WE HAVE VOLUNTARY INFORMATION SHARING PROGRAMS WITH INDUSTRY THAT CAN COME THROUGH SOMETHING AS SIMPLE AS AN E-MAIL OR TELEPHONE CALL OR SECURE POSTINGS ON THE PORTAL, THE ANALYTICAL STAFF WILL TRIANGULATE, SEE WHAT'S GOING ON, SEE IF THERE'S ONE OFF EVENTS SO IF WE SEE PATTERNS THAT WE CAN THEN ALERT OUR GOVERNMENT PARTNERS TO ISSUE OR INDUSTRY DEPENDING ON WHAT WOULD BE REQUIRED AND THEN THE REAL CHALLENGE FOR THE ISAC AND WE HEARD IT FROM NICK AND WE WEAR THIS EVERY DAY IS TAKING INFORMATION THAT WE GET AND FIGURING OUT WHEN DO YOU GET IT OUT. BECAUSE SOMETIMES IT'S MORE VALUABLE TO CHIEF SECURITY OFFICER TO GET A FAINT SIGNAL THAN A FULLY BAKED ACTION PLAN. SO ONE OF THE THINGS THAT WE'RE STRUGGLING WITH WITH OUR ADVISORS FROM INDUSTRY ON THE ISAC IS WHAT ABOUT SHOULD OUR THRESHOLD BE TO ALERTING FOLKS TO AN ISSUE AND HOW WELL DEFINED DOES IT NEED TO BE? AND THE FEEDBACK WE TEND TO GET IS GIVE US MORE, SOONER, RIGHT? BECAUSE THEIR CHIEF SECURITY OFFICERS WILL LOOK AT INFORMATION FROM THE ISAC PLUS MR. OWN SOURCES AND THEIR BETTER POSITIONED TO INTEGRATE THAT IN SOME CASES THAN WE ARE. SO OUR GOAL HERE IS WEAR NEVER GOING TO BE AS JENNIFER SAID, WILL EVER BE A ONE STOP SHOP THAT WILL BE THE ONLY SOURCE OF INTELLIGENCE IN THE SECURITY OFFICER WILL USE, OUR ASPIRATIONS IS TO BE A CRITICAL PART OF THAT CHAIN. AND TO THE EXTENT WE CAN TAKE THE PROGRAMS THAT WE DEVELOPED LIKE UPON CRISP AND FIND WAYS TO EXTEND THAT TO A BROADER SET OF ENTHUSIASMITS WOULD BE TO CREATE A SIMILAR TYPE OF PROGRAM FOR OPERATING TECHNOLOGY SO YOU UNDERSTAND WHAT MIGHT BE GOING OUT IN THE OPERATIONS OF THE SYSTEM. THOSE WOULD BE GREAT ADVANCES AND THE ISAC CAN PLAY AN IMPORTANT INTERMEDIARY ROLE BETWEEN INDUSTRY AND GOVERNMENT BECAUSE WE CAN SANITIZE AND DISGUISE INFORMATION SO THAT IT'S NOT ATTRIBUTABLE TO ANY PARTICULAR ENTITY. SO A WHOLE RANGE OF THINGS. YOU SHOULD COME VISIT.

SO AS YOU KNOW OUR INDUSTRY IS COMMITTED TO THE SUCCESS OF THE ISAC AND THAT'S WHY INDUSTRY EXECUTIVES HAVE USED REALLY THEIR VALUABLE TIME IN WORKING WITH NERC TO DEVELOP A MULTIYEAR PLAN TO INVEST OR RESOURCES IN THE EISAC TO IMPROVE INFORMATION SHARING TO MAKE SURE IT'S A TIMELY BASIS, TIM'S RIGHT. OUR COMPANIES INTERFACE WITH IA MULTITUDE OF DIFFERENT ENTITIES, GOVERNMENT, LOCAL, STATE, THE EISAC BUT THE KEY IS MAKING SURE THAT WE BELIEVE THAT THE EISAC CAN PLAY A VALUABLE AND NEEDED ROLE IN HELPING US SYNTHESIZE ALL THE INFORMATION WE'RE GETTING FROM DIFFERENT RESOURCES AND WE PARTICIPATE ACTIVELY ON I A NUMBER OF DIFFERENT LEVELS.

ONE MORE COMMENT BEFORE YOU ASK THE NEXT QUESTION, THE OTHER ISSUE IS WHAT THE ISAC HAS BEEN ABLE TO DO THAT WE HAVE HIGH HOPES TO APPROVE TO BE VALUABLE AS WE FORGE RELATIONSHIP WITH OTHER CRITICAL SECTORS. RIGHT SO WE HAVE A RELATIONSHIP WITH THE DOWN STREAM NATURAL GAS SECTOR AND WE SAID WITH THE SAME FACILITY THAT WE DO, WE CREATE A RELATIONSHIP WITH THE WATER ISAC AND THE MULTISTATE ISAC WE SERVE PUBLIC POWER ENTITIES, THE OIL AND NATURAL GAS ISAC SO IT CAN ALSO BECOME A FOLK AT POINT FOR CROSS SECTOR COLLABORATION AS WELL BECAUSE IF SOMETHING'S DEVELOPING ON THE NATURAL GAS SYSTEM THAT'S IMPORTANT FOR THE ELECTRIC SECTOR TO KNOW AS SOMETHING DEVELOPED WITHIN THE SECTOR ITSELF SO THAT'S ONE OF THE AREAS WE'RE TRYING TO EXPAND OUR REACH HORIZONTALLY AS WELL AS WITH IT.

DO HAVE YOU ANY INTEREST THAT IT'S EXACTLY 11:00 AND I'LL STAND DOWN ON THE REST OF IT.

THANK YOU ALL. WE WILL RECONVENE AT 11:15 FOR PANEL TWO. THANK YOU. [SPR-PL--PROGRAM IS ON A SHORT BREAK ]

AS THE CHAIRMAN MENTIONED HE STEPPED OUT ASK THEIR I'M AL HAG, AND I AM IN CHARGE, IF ANYBODY REMEMBERS THAT JOKE? MY STAFF DOES NOT SO NOW I KNOW HOW OLD I AM. WE WILL START THE PANEL NOW FOR CLOUD BASED SERVICES AND VIRTUALIZATION AND THIS DEALS WITH BOTH THE OPPORTUNITIES THAT TECHNOLOGY PROVIDES BUT PROVIDES NEW CHALLENGES TO NEW RISKS SO I LOOK FORWARD TO HEARING THE THE STATEMENTS AND WE WILL ALSO HAVE SOME INTERESTING QUESTIONS FOR YOU, I'M SURE. GO AHEAD, THANK YOU.

HELLO, EVERYBODY THANK YOU SO MUCH FOR HAVING ME TODAY I'M ASHLEY MAHAN AND I AM THE ACTING DIRECTOR OF FEDERAL RISK AND MANAGEMENT PROGRAM. IT'S A DELIGHT TO BE HERE TODAY BUT WHAT WE'RE FOCUSED ON IS CLOUD SERVICES AND TECHNOLOGY AND CYBERSECURITY SO WHEN THE GOVERNMENT IS LOOKING TO USE THESE CLOUD TECHNOLOGIES HOW THIS IS INFORMATION BEING PROTECTED IN THIS ENVIRONMENT AND THAT'S WHAT FED RAMP SETS OUT TO DO. SO EVERY PROCESS THAT SENDS FEDERAL INFORMATION WILL GO THROUGH THIS PROCESS IN GOVERNMENT. AND WE PARTICULARLY APPLY TO INFRASTRUCTURE OF SERVICE, PLATFORM AS A SERVICE AND SOFTWARE AS A SERVICE. THANK YOU.

GOOD MORNING I WANT TO SAY THANK YOU FOR THE OPPORTUNITY TO BE HERE TODAY AS A PANELIST AND AS THE NEW PERSON TO THE INDUSTRY, BE HONORED TO ADDRESS THE COMMISSION. MY NAME IS ANTWON JACOBSEN, I AM DIRECTOR OF I.T. SECURITY AT SMUD, AND ALSO CHIEF SECURITY INFORMATION, I'M ALSO HERE ON BEHALF OF THE ATTPA AND LTC TODAY. THE APPA AND THE LPPC SUPPORTS THE COMMISSION'S EFFORTS TO ENCOURAGE THE EVOLUTION AND THE POTENTIAL ADOPTION OF CLOUD SERVICES AND VIRTUALIZATION, WITH THE REGISTERED ENTITY WILL BE AFFORD THE OPPORTUNITY TO DECIDE IF LEVERAGING THESE TECHNOLOGIES AND SERVICES ARE APPROPRIATE FOR THEIR OWN ORGANIZATION. INDUSTRY IS UNCERTAIN IF THEY CAN BE LEVERAGED WHILE CLOUD BASE SERVICE OFFERING CONTINUE TO INCREASE AS VENDORS MOVING MORE AND MORE OF THESE SERVICES TO THE CLOUD. THE APPA, AND LPC RECOGNIZE THAT WITH THEM COMES A GREATER NEED TO UNDERSTAND ASSOCIATED SECURITY RISK AND COMPLIANCE OBLIGATIONS, IT'S IMPORTANT THAT THE ELECTRIC INDUSTRY, ENTIRE APPROXIMATE NERC AND FERC RECOGNIZE THAT WHILE VIRTUALIZATION AND CLOUD SERVICES ARE RELATED THE BARRIERS OF OTKOPGZ OF EACH ARE DIFFERENT. MANY ENTITIES USE CLOUD SERVICE PROVIDERS TO MANAGE BUSINESS PROCESSES OUTSIDE OF POWER SYSTEMS AND OPERATIONS TO INCREASE VISIBILITY AND TO SYSTEM OPERATIONS AND SECURITY. IMPROVE SYSTEMS, AVAILABLE AND REDUCE RESOURCE REQUIREMENT. IF DONE WITH CARE, CLOUD SOLUTIONS CAN REDUCEISK, INCREASE FLEXIBILITY AND SECURE THE POPULATION SYSTEM, THANK YOU AGAIN AND LOOKING FORWARD TO QUESTIONS FROM THE COMMISSION TODAY. NGOOD MORNING, THANK YOU COMMISSION FOR THE OPPORTUNITY TO SPEAK TO YOU ON CLOUD SERVICES. THESE ARE OPPORTUNITIES THAT CAN TRANSFORM OUR OPPORTUNITY AND MAKE OUR SYSTEMS MORE RELIABILITY RESILIENT AND SECURE, THESE ARE TOOLS TO SOLVE PROBLEMS NO DIFFERENT IN REGARD TO SERVERS, DATABASES AND SOFTWARE, TOOLS WE USE EVERY DAY. IT'S FORTUNATE RECALL THAT THERE WAS A TIME WHEN EACH OF THESE TECHNOLOGIES WAS NEW, UNTESTED AND NOT CONSIDERED INDUSTRY STANDARD. TODAY IS DIFFICULT TO IMAGINE MOW WE COULD DO OUR WORK EFFECTIVELY AND EFFICIENTLY WITHOUT THESE TECHNOLOGIES. I BELIEVE THIS IS A HENCE THROUGH WHICH WE CAN VIEW CLOUD SERVICES. AT MISO, I SPENT EIGHT YEARS AS DIRECTOR OF I.T. INFRASTRUCTURE AS PRIOR TO MY CURRENT ROLE OF INFINIT RESPONSE SYSTEM RECOVERY. HAVING THE RESPONSIBILITY FOR ALL SERVERS, NETWORK, STORAGE, DESKTOP AND CELL COMSYSTEMS FOR EIGHT YEARS MEANS I UNDERSTAND THE IMPORTANCE OF RELIABILITY AND SECHIITY. ALSO LED NERC REPORTING INITIATIVE AND DRAFTING TEAM AND THE INFORMATION IN THE CLOUD. AND THE INFORMATION WHETHER CLOUD SERVICES HAVE A PLACE IN INDUSTRY BUT RATHER THE QUESTION IS WHEN. MAJOR SOFTWARE VENDORS HAVE QUICKLY FROM A CLOUD FIRST TO A CLOUD ONLY MIND SET AND THAT TELLS US THAT OLDER NONCLOUD TECHNOLOGY FROM WHICH WE RELY ON TODAY WILL NOT BE SUPPORTED INDEFINITELY, OURICAL SEFRPBL TO APE HOW CLOUD SERVICES ARE INTENDED TO OUR INDUSTRY'S CORE MISSION OF RELIABILITY AND SECURITY AND FERC AND NERC HAVE A ROLE IN THIS EFFORT. CLOUD SERVICES CAN BE DIFFERENT THINGS TO DIFFERENT PEOPLE, NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY FOR THE SOLID DEFINITION AND CLOUD SERVICE TO INCLUDE THE FOLLOWING, ON DEMAND, BROAD ACCESS, RESOURCE POOLING, RAP ED ELASTICITY AND MEASURE SERVICES. AND THIS DEFINITION PERFORMS THESE COMMUNITIES AND IN ADDITION TO RELIABILITY AND SECURITY CLOUD COMPUTING OFFERS OTHER BENEFITS IN INDUSTRY, INCLUDES REDUNDANCY, RESILIENCE SKPE BAKUGAN RECOVERY OF SYSTEMS. THE RAPID SCALABLE OF THESE ORGANIZATIONS TPHAOEUGZS REFLECTS THEM WITH THE RIGHT SECURITY IN PLACE, CLOUD SERVICES PROVIDES--PROVIDER CANS RESPOND RAPIDLY TO AN INVOLVING THREAT ENVIRONMENT. UNDER THESE SERVICES CARRY CONCERNS FOR EXAMPLE ENSURING AVAILABILITY OF THE SYSTEM IS VITAL AS GRADE OPERATORS AND UTILITIES WE UNDERSTAND AND STRIVE FOR A HUNDRED PERCENT AVAILABILITY. WE MUST WORK TO INSURE THAT THE INDUSTRY CAN SAFELY AND RELIABLY NAVIGATE TRANSITION TO THESE CLOUD SERVICES. THESE CONCERNS TYPICALLY DISSUADE THE INDUSTRY FROM CLOUD SERVICES. THE FIRST, HOW DO WE SECURELY MANAGE BEST CYBER SYSTEM IN THE CLOUD AND SECOND HOW DO WE SECURELY AND RELIABLY MANAGE BEDSIDE SIZES IN THE CLOUD. THE FIRST CONCERN IS WITH INFORMATION MANAGEMENT AND WHILE THE SECOND IS MORE CHALLENGING, AS IT TOUCHES ON HOW WE MOVE OUR CRITICAL SYSTEM TO THE CLOUD AND MAINTAIN PHYSICAL SECURITY, CYBERSECURITY AND RELIABILITY WHEN WE DO SO. WE IN INDUSTRY AND OUR REGULATORS MUST CONSIDER HOW REGULATORY REQUIREMENTS ADAPT TO SUCH A RAPIDLY EVOLVING SET OF CHANGES AND HOW WE CONTINUE TO INNOVATE AND ENHANCE RAOEUBLT AND RESILIENCE AND SECURITY IN OUR SYSTEM. THERE'S NO LONGER A QUESTION OF HOW CLOUD IS IN THE INDUSTRY, THE QUESTION IS WHEN IT WILL WORK FOR OUR INDUSTRY. THE INDUSTRY WOULD BENEFIT FROM A FOCUSED ATTENTION BY THE COMMISSION TO ADVANCE THE AVAILABILITY OF COMPANIES TO APPROPRIATELY INCORPORATE LEVERAGE THE ECONOMIC RELIABILITY FOR CLOUD COMPUTING. TECHNOLOGIES AND INNOVATIONS ARE OUTPACING NERC STANDARD DEVELOPMENT ESPECIALLY IN THE SPACE, WE RECK PHEPD THE COMMISSION FURTHER ENGAGE INDUSTRY AND KEY CLOUD SOLUTION PROVIDERS AND DEVELOPERS IN ONE OR MORE TECHNICAL CONS FERENCES TO CLARIFY ISSUES AND DIRECT TIMELY INDUSTRY ACTION TO ESTABLISH A WAY FORWARD WITH CHANGES TO CIP STANDARD SPECIFICALLY TO ACCOMMODATE CLOUD SERVICES, THANK YOU.

GOOD MORNING AND THANK YOU, I'M MICHAEL BALL AND I'M THE CHIEF SECURITY OFFICER FOR BERKOVITZSHIRE HATHEWAY ENERGY. IT'S A PRIVILEGE TO BE HERE TO TALK ABOUT THIS IMPORTANT TOPIC, WHEN IT COMES TO CLOUD COMPUTER AS IT RELATES TO HOW WE OPERATE OUR BUSINESS, NOT ONLY AS A BUSINESS SYSTEMS BUT ALSO OUR OPERATIONAL SYSTEMS, YOU KNOW THERE'S NO QUESTION THAT CLOUD IS NOT ONLY A PART OF THE FABRIC OF THE WAY WE MANAGE TECHNOLOGY TODAY BUT IT IS CLEARLY A PATH TO THE FUTURE AS WELL, SO THE DISCUSSION IS GOING TO BE IMPORTANT AND I BEING THREE BASIC PREMISES THAT I WOULD FOCUS MY CUSHION ON TODAY, THE FIRST ONE JUMP SIMPLY THAT CLOUD SOLUTIONS ARE UPON US TODAY AND ALL OF OUR ENTERPRISE BUSINESSES AND CORPORATE I.T. ARENA IF YOU ARE WORKING WITH THIRD PARTIES, YOU ARE OFTEN UPON TIMES WORKING WITH THIRD PARTIES THAT ARE IN FACT UTILIZING A CLOUD SERVICE. WE ARE IN AN--AD A TIME WHEN CLOUD SERVICES ARE UNCLEAR IN TERMS OF THE RELATIONSHIPS WE HAVE, HOW WELL DO OUR THIRD PARTIES MANAGE THESE. THESE ARE ALL PART OF THE DISCUSSION WE NEED TO HAVE RELATIVE TO THIS BUT IT IS UPON US TODAY. IN OUR ORGANIZATIONS FLIESATION WE'RE VERY CONSERVATIVE ABOUT HOW WE EMBRACE IT AND I'LL TALK MORE ABOUT THAT. BUT I THINK IT'S IMPORTANT TO REALIZE THAT WE HAVE TO BE EXCELLENT, WE HAVE TO EXCEL IN OUR ABILITY TO LEVERAGE AND MANAGE CLOUD BASED AND VIRTUALIZATION TECHNOLOGY. THE SECOND PART OF THAT IS REALLY YOU CANNOT OUTSOURCE RISK, OFTEN TIMES SERVICE PROVIDERS WILL COME TO YOU WITH THE CONCEPT OF THIS A MORE SECURE UPON PLATFORM, WE WILL HEAR ABOUT SERVICES THAT HAVE TREMENDOUS OPPORTUNITY WELL ABOVE WE WILL BE ABLE TO HAVE WITH ENTERPRISES BUT IT'S NOT THE THIRD PARTY, THE SERVICE PROVIDER THAT PROVIDES SECURITY, IT IS US AS THE ENTITY, WE ARE ACCOUNTABLE. I'M ACCOUNTABLE FOR MAKING SURE WE DEPLOY CLOUD BASED TECHNOLOGIES IN A SECURE AND RELIABLE MANNER. SO THAT IS GOING TO BE ESSENTIAL IN THE WAY WE DOURE ON BUSINESS. YOU KNOW I THINK THAT IS WHERE WE INHERIT SIGNIFICANT RISK AS WELL. BECAUSE THE QUESTION IS, IS IF I CAN ASSERT TO YOU THAT I MANAGE A VERY--OUR ENVIRONMENT AND OUR SERVICES IN A SECURE MANNER, CAN I ASSERT THAT THE THIRD MATTERS ARE DOING THE SAME WHEN THEY DO THE SAME WHEN THEY LEVERAGE THE CLOUD? AND THAT'S A DIFFICULT CONVERSATION. IT'S DIFFICULT TO PROVE THAT SO WE NEED TO CONTINUE TO EVOLVE OUR CAPABILITIES IN THE SPACE AND PUT EXPECTATIONS ON THOSE THIRD PARTIES BUT WE OWN THE RISK. SO IT'S A CENTRAL PART OF THAT AND THIRDLY AND LASTLY, REALLY, WE NEED TO LOOK AT RELATIVE TO STANDARDS THAT THE WAY THEY'RE DEFINED, RIGHT NOW THE NERC CIP ASSETS ARE AROUND THAT BUT AS WE TRANSITION INTO CLOUD BASED SOLUTIONS THIS IS NOT AN ASSET BASE SOLUTION. IT'S A COMPLEX NETWORK OF ASSETS THAT WORK TOGETHER AS A SYSTEM. AND SO, HOW DOES THE LANGUAGE IN TERMS OF OUR STANDARDS APPLY TO US WHEN WE WANT TO EVIDENCE OUR COMPLIANCE FROM A PARTICULAR STANDARD. SO THAT IS WHERE WE HAVE A TREMENDOUS OPPORTUNITY TO PARTNER TOGETHER AND THE COMMISSION HAS A TREMENDOUS OPPORTUNITY TO PARTNER WITH INDUSTRY HO HOW DO WE TACKLE THE VIEW OF--HOW DO WE MAKE SURE WE SECURE THESE ASSETS. NOW DO WE DEMONSTRATE WE CAN SEE CURE THEM WHEN WE LEVERAGE THEM WHERE THIRD PARTIES AREA I SIGNIFICANT PART OF THE EQUATION, SO THAT'S WHAT I SEE AS A CHALLENGE. IT'S A GREAT OPPORTUNITY THOUGH FOR US TO TACKLE AND I LOOK FORWARD TO ADDITIONAL CONVERSATION AROUND THE TOPIC. THANK YOU VERY MUCH FOR THE OPPORTUNITY TO BE HERE.

ON BEHALF OF PPL ELECTRIC UTILITY, THANK YOU FOR INVITING ME TO PARTICIPATE IN THE FERC TECH NEUROECTODERMALICAL CONFERENCE, WE SERVICE 1.4 MILLION SQUARE MILES OF PEOPLE IN THE PENNSYLVANIA AREA, WE HAVE 127 J. D. QUALITY POWER AWARDS TO OUR RESIDENCES AND CUSTOMERS. WE BELIEVE IT INCORPORATING NEW TECHNOLOGY MEETS RAOEUBLT AND MEETS CUSTOMER'S CHANGING EXPECTATIONS, OUR COMPANY RESEARCHED AND IMPLEMENTED TECHNOLOGIES AND VIRTUALIZATION FOR DATA ANALYTICS FOR PREDICTIVE MAINTENANCE AND WE ARE SEEING BENEFITS. AS NEW TECHNOLOGIES ARE IMP LETTED WE MUST REMAIN VIGILANT TO RESPOND TO THE EVER CHANGING CYBER AND PHYSICAL THREATS AGAINST OUR INDUSTRY. WHILE WE'RE COMMITTED TO MEETING THE RELIABILITY STANDARDS WE SEE THEM AS ONLY A MIN NUM REQUIREMENT, OUR FOCUS IS ON RELIABILITY AND SECURITY AND SUBSEQUENTLY WE EXPECT TO EXCEED THE COMPLIANCE REQUIREMENT, WE WANT TO CONTINUE IMPLEMENTING NEW TECHNOLOGIES, THE NEW TECHNOLOGIES CAN PROVIDE A STEP LEVEL INCREASE IN DAILY OPERATIONS, SUCH AS FASTER SECURITY PATCHING, MORE ROBUST ACTIVE MODELS AND IMMEDIATE SCALABILITY. IF USED IN THE SECURE MANNER, THESE TECHNOLOGIES CAN HAVE MAJOR BENEFITS. SELECTING THE MOST COST EFFECTIVE TECHNOLOGY WITH APPROPRIATE SECURITY MODELS IS BENEFICIAL FOR OUR CUSTOMERS. AT THE SAME TIME COST RECOVERY FOR ON AND OFF PREMISE INFRASTRUCTURE MUST BE CONSIDERED. WE SUPPORT THE NERC THAT SET SECURITY STANDARDS WITHOUT LIMITING OPTIONS, DEVELOPING STANDARDS AND ENABLE NEW TECHNOLOGIES WITHOUT MAJOR CHANGES WILL BE A WIN FOR THE ENTIRE INDUSTRY. EMERGING TECHNOLOGY SHOULD BE EVALUATED FOR THEIR IMPACT TO RELIABILITY SECURITY AND OUR CUSTOMERS. MANAGED SERVICE PROVIDERS, HAVE A ROLE IN OUR SUCCESS OR FAILURE AS THE INDUSTRY MOVES OFF PREMISE WITH INFRASTRUCTURE, PLATFORM AND SOFTWARE SECURITY AS A SERVICE. THE INDUSTRY NEEDS THE PARTNERSHIP FROM THE MSP. CLEAR ROLES AND RESPONSIBILITIES FOR THE VARIOUS RISK AREAS IS CRITICAL, PPL SUPPORTS THE MODEL OF INDEPENDENT THIRD PARTY ASSESSMENTS AND INDEPENDENT MONITORING TO ASSURE SERVICES INCLUDING SECURITY POSTURE TO THE REGISTERED ENTITY AND THE EARE, O. SIMILAR TO THE INDEPENDENT TESTING FOR COMPLETENESS AND ACCURACY OF FINANCIAL DATA UNDER THE SARBANESOXLY SECTION FOUR, THE ERO COULD PROVIDE SAMPLING OR INDEPENDENT ASSESSMENT AND CERTIFICATION OF THE MSP SECURITY PROGRAM. PPL RECOGNIZES THERE ARE STILL UNKNOWNS THAT NEED RESEARCH AND COLLABORATION, EMBRACING EMERGING TECHNOLOGY SYSTEM REQUIRED TO MEET THE FAST PACED CHANGES IN THE INDUSTRY AND EXTERNAL FORCES EFFECTING OUR INDUSTRY. WE ARE MINDFUL OF THE PROCESS CHANGES THAT ARE NEEDED AS WELL AS THE NEED TO UNDERSTAND AND ADDRESS THE NEW RISKS. WE ARE LOOKING FORWARD TO THE ERO FOR STAKEHOLDERS TO MAIN TAN A SECURE POWER GRID TO MEET THE NEEDS OF TOMORROW.

GOOD MORNING, THANK YOU VERY MUCH FOR THE OPPORTUNITY TO TALK ABOUT AMAZON WEB SERVICES ON THIS IMPORTANT TOPIC WITH ALL OF YOU, I AM MICHAEL SOUTH I LEAD THE IS SECURITY COMPLIANCE ACROSS MARRYING, RATHER THAN STARTING OFF WITH TALKING ABOUT AWS AND OUR CAPABILITY AND SERVICES I WOULD LIKE TO SHARE WITH YOU MY PERSONAL JOURNEY TO THE CLOUD FROM A SECURITY PERSPECTIVE SO I SPENT 25 YEARS IN THE U.S. NAVY WHERE I LED THE OPERATIONS OF NETWORKS AND DATA CENTERS WITHIN EUROPE, I WAS A CIO FOR JAPAN AND LEAD FOR CYBER SECHIITY FOR THE NAVY NATION, IN THAT ROLE I MANAGED TRADITIONAL DATA CENTERS AND NETWORKS AND IN A VERY STRINGENT AND STRICT SECURITY POSTURE SIMILAR TO WHAT YOU SEE IN REGULATED INDUSTRY TODAY. WHEN I LEFT THE NAVY, I WENT TO THE CITY OF WASHINGTON D. KREBS CYCLE WHERE I WAS SUSPECT CISO FOR THE DEPUTY OFFICER FOR THE CITY FOR THE FOCUS ON GOVERNANCE AND COMPLIANCE. WHEN I ARRIVED THE CITY WAS STARTING TO MOVE TO THE CLOUD, THE DC HEALTHCARE EXCHANGE WAS GOING TO AWS. WHILE I HAD USED SERVICES SUCH AS DROP BOX ON A PERSONAL LEVEL, AT A PROFESSIONAL LEVEL WITH MY SECURITY BACKGROUND UNDERSTANDING, YOU KNOW THE THREATS ARE OUT THERE FROM THE VERY MUNDANE TO NATION AND STATE, I WAS COMPLETELY AGAINST THE CITY MOVING TO THE CLOUD, WE HAD JUST ABOUT EVERY TYPE OF COMPLIANCE REQUIREMENT HAD TO BE MET, FOR SCHOOLS, POLICE DEPARTMENT, CREDIT CARDS, YOU MAIM IT PRETTY MUCH EXISTED WITHIN THE CITY AND I WAS VERY ADAM ANT AGAINST MOVING TO THE CLOUD. HOWEVER, BEING A SECURITY PROFESSIONAL I PRIDE MYSELF ON NOT BEING THE DEPARTMENT OF [INDISCERNIBLE] I TOOK IT UPON MYSELF TO LEARN TO FIGURE OUT WHAT CLOUD AND AND WHAT IT'S NOT BECAUSE IT'S A VERY NEBULOUS TERM, THERE'S A LOT OF MISINFORMATION OUT THERE AND LABELS SLAPPED ON PRODUCTS THAT CAN BE MISLEADING AS TO WHAT IS THE CLOUD SO I TASKED MYSELF AND MY STATE REGULATOR OF TO LEARN ABOUT WHAT THE CLOUD WAS HOW WE ACHIEVE OUR OBJECTIVES IN THE CLOUD AND MEET OUR REQUIREMENTS, NOW IT DIDN'T TAKE THIS LONG TO FIGURE OUT THAT YES WE COULD REALLY ACHIEVE ALL OF THAT. SOME OF THE SERVICES, SOME OF THE TECHNOLOGIES MIGHT BE DIFFERENT PEW WE COULD ACTUALLY ACHIEVE THOSE SAME RESULTS WITHIN THE CLOUD. IT ALSO HIGHLIGHTED A COUPLE THINGS THAT WE WEREN'T EXPECTING. WE HAD GOTTEN TO THE POINT WE HAD OUR OWN ENVIRONMENTS THAT WE GOT USE TO HOW THINGS ARE, THE REALITY OF OF THE SITUATION AND WITH THE CLOUD SORT OF HIGHLIGHTING FOR US WAS SIGNIFICANT IMPROVEMENTS WE WERE NOT EXPECTING THE FIRST WAS VISIBILITY SO WHEN YOU LOOK AT YOUR TOP CIS 20 CONTROLS ONE AND TWO IS INVENTORY OF YOUR NETWORK, HARD WORK AND SOFTWARE, THAT'S A BIG CHALLENGE IN TODAY'S ENVIRONMENT AND IT KIND OF GOES AGAINST THE PARADIGM IF YOU PHYSICALLY OWNER YOUR SERVERS YOU PHYSICALLY CONTROL DATA CENTERS THAT SOMEHOW YOU HAVE GREATER VISIBILITY BUT IN TODAY'S VIRTUAL WORLD, THAT REALLY DOESN'T HOLD WATER ANYMORE. AND THEN FROM THERE, YOU WOULD BE SURPRISED THE NUMBER OF CRITICAL APPLICATIONS FOR MILITARY CITIES, GOVERNMENTS AND SO FORTH THAT WILL LIVE IN ONE SERVER STACK AND ONE DATA CENTER, IF THERE'S A FAILURE, THAT ISN'T HELD DOWN FOR WHAT THE MISSION IS THAT'S UNACCEPTABLE SO WE CEIVE SEEN THE RELIABILITY AND RESILIENCY OF CLOUD IS QUITE SIGNIFICANTLY DIFFERENT AND SOMETHING WE WERE NOT EXPECTING AND THE LAST THING FROM THE SECURITY ROMERATIONS PERSPECTIVE AND THE ABILITY TO AUTOMATE. THE ONLY WAY WE WERE ABLE TO KEEP UP WITH THE CYBERSECURITY THREATS OF TODAY IS TO AUTOMATE REMEDIATED ACTIONS, A HUMAN AS GREAT AND SMART AS WE CAN BE, WE CANNOT KEEP UP WITH THE NUMBER OF ATTACKS AND EFFECTS THAT ARE OCCURRING IN OUR ENVIRONMENT TO DO THE RESEARCH AND DO THE MITIGATING ACTIONS, WE HAVE TO BE ABLE TO AUTOMATE, SCALE AND KEEP UP WITH THOSE THREATS.

THANK YOU ALL, AND THANK YOU ALL FOR BEING HERE AND TAKING YOUR TIME TO JOIN US AND PROVIDE THE INFORMATION. ONE THING I THINK HAPPENS IS WE LOOK AT THE USE OF TECHNOLOGY WE KEEP HEARING ABOUT THE PRESS, AND TECHNOLOGY AND WE DON'T FOCUS ENOUGHOT BENEFITS OR THE TECHNOLOGY IS, WE WILL GET INTO THE THREAT ISSUES BUT I WOULD LIKE YOU ALL TO TALK A LITTLE BIT ABOUT, A BIT MORE ABOUT WHAT YOU SEE THE BENEFITS OF VIRTUALIZATION BUT NOT JUST CLOUD BUT A BENEFIT FOR UTILITIES THOSE WHO ARE ULTIMATELY THAT TRICKLES DOWN TO RATE PAIRS IF ANY OF YOU CAN CHOOSE TO ANSWER THAT.

I'LL TAKE A--BITS INITIAL CUT AT THAT--AN INITIAL CUT AT THAT. A GOOD QUESTION BECAUSE WHEN WE LOOK AT THE TYPES OF CLOUD SERVICES THAT ARE OUT THERE, WE SEE A LOT OF OPPORTUNITIES NOT ONLY TO LEVERAGE IT BUT IT'S A REAL ENABLER, IN OUR CASE, YOU KNOW WE HAVE ONE OF THE GREAT OPPORTUNITIES TO TAKE DAT FROM DISPARATE LOCATIONS TO AGGREGATE THAT, TO BE ABLE TO DO, YOU KNOW BIG DATA ANALYTICS AND CLOUD TYPE SOLUTIONS ARE REALLY BIG SIGNIFICANT ENABLERS EVER THAT WHERE WE MIGHT HAVE HAD TO HAVE VERY LOCALIZED DATA POINTS AND BE ABLE--YOU KNOW HOW DO YOU DO THAT ON PREMISES AND LOAD YOUR NETWORKS UP AND TRY TO GATHER THAT. WE FOUND THAT, YOU KNOW WE'VE BEEN ABLE TO EXTRACT DATA NOT HAVING A CLOUD PRESENCE WITHIN OR OPERATION WITHIN OUR CONTROL ENVIRONMENT BUT BE ABLE TO EXTRACT DATA OUT AND THEN AGGREGATE IT AND THEN DO THE ANALYTICS AND IT ALLOWS US TO LOOK AT ASSET BASE, PERFORMANCE, HOW DO WE OPTIMIZE IT, THE OPERATION OF THAT. I THINK THAT LEADS INTO OUR ABILITY TO HAVE A BIT MORE CONSISTENT, RELIABLE ENERGY GENERATION. SO I THINK THESE ARE GOOD WAYS TO LEVERAGE THAT TECHNOLOGY AND BEING ABLE TO AGGREGATE AGAIN DATA FROM DISPARATE LOCATIONS THROUGHOUT OUR VARIOUS NETWORKS, WE COVER ROUGH LIE 18 STATES.

I'LL JUST ADD FROM MY STANDPOINT, YOU KNOW ONE OF THE INSIGHTS THAT I'VE GATHERED IN THIS ROLE OVER THE PAST FEW YEARS AND THAT INDUSTRY IS CONSTANTLY RESEARCHING AND DEVELOPING INNOVATION AND LOOKING TO APPLY SECURITY TO THEIR TECHNOLOGY, THIS IS THEIR CRAFT, RIGHT? THIS ISN'T AN AFTERTHOUGHT FOR THEM. SO IF THERE'S A WAY WE CAN HARNESS THIS INNOVATION, IN THE CLOUD, INSURE AND UNDERSTAND FROM A TRANSPARENCY STANDPOINT HOW OUR INFORMATION IS BEING PROTECTED, WE DON'T WANT TO RECREATE THE WHEEL INTERNALLY WITHIN OUR OWNINIZATION, RIGHT, SO IF WE ESTABLISH THAT PROCESS SWHICH RAMP IS ENABLER OF OF HOW THE DATA IS PROTECTED, HOW IT'S USE INDEED THESE ENVIRONMENTS AND THE CONSTANT VIGILANCE THAT IT'S HRARPLGLY INDUSTRY PROVIDER, ROUGH ATOM VIEDING AND GIVE US CLUMSY INSURANCE THAT OUR INFORMATION IS SAFE GUARDED PROPERTILY WITH THE NEEDS ENVIRONMENT. I WILL ADD TO THAT AS WELL, AND I SEE BENEFITS THERE IN LEVERAGING EXPERTISE AS SERVICE PROVIDERS AND CLOUD SERVICE PROVIDERS AND BENEFITS TO ACTUALLY LEVERAGE SOME OF THE SERVICES IN OFFERS AND AND INTO OFFERING AND RIGHT NOW, CHALLENGE WITH THE DATA AND TAKING THAT DATA AND--MENTION THE PROCESS AND MISO, ONE OF THE LONGEST PROCESSES YOU HAVE IT'S TAKES LONG TIME--ONE OF THE THINGS THAT VIRTUALIZATION DOES IS IT ALLOWS US TO BUILD ON THAT AND BUILD FROM TEMPLATES AND READY TO GO AND ALSO STUFF FOR THAT AND THERE'S ANOTHER PIECE THAT'S BIG AND FROM THE RECOVERABILITY PERSPECTIVE WHEN YOU THINK ABOUT VIRTUALIZATION, A VIRTUAL MACHINE IS REALLY JUST A BIG FILE WITH A CONFIGURURATION APPLIED TO IT AND SO WHEN YOU WANT TO ACTUALLY DO A RECOVERY IT MAKE ITS VERY SIMPLE AND VERY QUICK. MATTER OF FACT, THE CIP REQUIREMENTS AND R2.3 LAST YEAR WHICH SAID YOU HAD TO OPERATIONALLY TEST YOUR BACK UP AND RECOREY PROCESS WITHIN EVERY THICKS MONTHS WHAT WE FOUND WAS RECOVERING OUR VIRTUAL MACHINES WAS SO SIMPLE AND FAST BECAUSE WE COULD RECOVER A FILE AND APPLY A STATE TO IT AND WE WERE BACK UP AND RUNNING WHEN WE HAD TO RECOVER THE PHYSICAL SERVERS IT TOOK A SIGNIFICANT AMOUNT OF TIME AND SOMETIMES WE FAILED SO WE HAD TO REINVENT OUR PROCESS, SO THERE'S BENEFITS THAT VIRTUALIZATION AND CLOUDURE THAT ARE BEYOND THE SECURITY MODEL.

I'D LIKE TO ADD THAT THERE IS A THERE ARE RESOURCE CONSTRAINTS FROM AN IT AND CYBER SECHIITY PERSPECTIVE AND THERE'S A NUMBER WHERE THERE'S A SHORTAGE OF QUALIFIED CANDIDATES AND IT'S THE ENTIRE INDUSTRY IS COMPETING FOR THOSE SAME RESOURCES AND MANY OF THEM WANT TO GO TO THE--YOU KNOW TO THE GOOGLE AND TO THE AMAZON AND TO THE SNAZZY PLACES AND NOT THE UTIL WE'RE AT A LOSS FOR THAT.

THE FACT IS HARDWARE FAILS, IT WILL ALSO FAIL AT SOME MOMENT IN TIME WHEN YOU HAVE A CRITICAL APPLICATION TIED TO HARDWARE, YOU WILL BE RELYING ON WHEN THAT HARDWARE IS REPIE AND/OR REPLACED WHICH WILL TAKE YOU A LONGER TIME PERIOD AND THE ABILITY OF VETERINARY RESOURCESSUALIZATION AS MR. ROSENTHAL HIGHLIGHTED YOU WERE ABLE TO TAKE THAT FILE, THAT VIRTUAL SERVICER AND RESTORE IT ON ANY PIECE OF HARDWARE THAT YOU HAVE AVAILABLE OR WITHIN THE CLOUD, WITHIN A FEW MINUTES, OKAY? SO THAT RIGHT OFF THE BAT IS A BIG WIN FOR THAT DISASTER RECOVERY BUT TAKE ANOTHER STEP FURTHER WHEN BUILD THAT APPLICATION ON RESILIENT INFRASTRUCTURE WHERE HAVE YOU A SINGLE APPLICATION SPANNING SERVER DATA CENTERS AND DATA CENTER FAILURE, YOU ARE ABLE TO LOAD BALANCE ACROSS THAT SO YOU'RE APPLICATION AND YOUR CUSTOMERS YOU KNOW NEVER SEE AN OUTAGE. SO WITHIN SECONDS, THE ACTUAL INFRASTRUCTURE PROVIDES A SELF-HEALING OPPORTUNITY SO THAT WHEN A SERVER FAILS IN ONE DATA CENTER OR A WHOLE DATA CENTER FAILS, EVERYTHING IS LOAD BALANCED OVER, IT SELF-HEALS, SPINS UP NEW SERVERS TO FAIL THE SERVER AND REDISTRIBUTING THE LOAD AGAIN, SO IT'S SELF-HEALING. THIS,A LOWS YOU TO SHIFT FROM A REACTIVE SCARFY RECOVERY RISK MODEL MODEL TO A PROACTIVE RESILIENCY RISK MODEL SO YOU NEVER GET RISKS DOWN TO ZERO BUT YOU MITIGATE THAT ON THE FRONT END RATHER THAN HAVING TO DEAL ON THE BACK END AND RELY ON BACK UPS.

AND LET ME FOLLOW UP ON THAT POINT IS THAT AS MORE AND MORE THE INDUSTRY MOVES TO USING--USE THE CLOUD, ARE THERE MULTIPLE--YOU KNOW ARE THERE MULTIPLE DATA CENTERS THAT HAVE THE SAME INFORMATION OR SHARE THE SAME INFORMATION SO THAT IF ONE DATA CENTER GOES DOWN YOU'RE NOT GOING TO BE WIPING OUT INFORMATION NECESSARY FOR A WHOLE GROUP OF UTIL UTS TO OPERATE AS OPPOSE TO ONE USING THEIR ABILITY TO OPERATE.

YES, SIR THAT DEPENDS ON THE SERVICES YOU SPECIFICALLY WANT TO USE, SO IN AWS WE HAVE OVER 160 SERVICES SO ONE SERVICE IS THE STHREE, THE OBJECT STORE WITH YOU PUT FILES INTO. WHEN YOU SUBMIT A FILE INTO STHREE, WHAT WE CALL AN S-THREE POCKET LIKE A HARD DRIVE, WE CALL IT A BUCKET WHEN YOU SUBMIT THAT FILE INTO A BUCKET IT'S DISTRIBUTED ACROSS AT LEAST THREE DIFFERENT DATA CENTERS WITH THE REGION, OKAY, SO WITHIN THAT, IN ADDITION THORS THAT, THAT FILE IS WE CALL SHARDED SO IT'S SPLIT UP ACROSS PUT PEL PLATFORMS IN THAT SO ONE WE CAN GO INTO A WHOLE OTHER DISCUSSION ABOUT PHYSICAL SECURITY BUT IF SOMEBODY HIT A HARD DRIVE THEY WOULD NOT GET ALL THE DATA, I THEY WOULD GET A PIECE AND THE WAY IT'S SHARDED IT'S UNINTELLIBLE FOR THEM SO IT'S CONNIEED SO IF YOU LOSE THE DATA CENTER OR WE LOSE ANYTHING THAT'S PRESENTED BACK WE DON'T ACTUALLY LOSE THE DATA SO S-THREE HAS THE DURABILITY OF 11-NINES SO ANOTHER 99-AND ANOTHER 99 PERCENT AVAILABLE AS FAR AS NOT LOSING THE DATA. AS FAR AS VIRTUALIZATION SERVERS, THAT AT SERVICE WE HAVE THAT PROVIDES VIRTUAL SERVICE. EC-TWO IF YOU ONLY HAVE THE ONE INSTANCE, THAT'S ONE SERVER THAT WILL BE IN ONE DATA CENTER. YOU WILL WANT TO ARCHITECT YOUR APPLICATION SO THAT THERE ARE ACTUALLY MULTIPLE AT LEAST TWO, IF NOT THREE IN DIFFERENT DATA CENTERS, AND THE WAY YOU DO THAT WITH AWS IS YOU SELECT AN AVAILABILITY ZONE, IT'S A LOGICAL FAULT ISOLATION ZONE SO THIS IS HOW OUR DATA CENTERS ARE GROUPED AND WITHIN EACH AVAILABILITY SO THAT IF WE LOSE A DATA CENTER, AND THE ABILITY TO THE DATA CENTERS SO YOU DON'T LOSURE YOUR APPLICATION SO VARIES DEPENDING ON SERVICE AND INHERENT SO YOU DON'T DO ANYTHING OTHER THAN TURN IT ON AND USE IT, OTHERS YOU ARCHITECT FOR THAT.

THAT'S HELPFUL AND THAT GOES THEN TO THE SECOND PART AND THAT IS YOU MADE THE INFORMATION THAT YOU CAN'T OUTSOURCE,--OUTSOURCE THE RISK. HOW SHOULD WE LOOK AT, YOU KNOW CLEARLY AMAZON AND OTHERS HAVE ALREADY THOUGHT ABOUT DIFFERENT RISK AND SO THEY OFFER SERVICES THAT HELP MITIGATE THOSE RISKS, BUT HO DO WE INSURE THAT THE UTILITIES, THE PARIT TIS PANTS ARE NOT OUTSOURCING THAT RISK AND JUST RELYING TO MAKE SURE THAT WE ARE HAVING AT LEAST A GOOD MINIMUM STANDARD TO MAKE SURE THAT THE SERVICES THAT ARE PURCHASED FROM CLOUD SERVICES THAT THEY'RE SUFFICIENT IN ORDER TO PROTECT THE SYSTEM ULTIMATELY.

SO I MIGHT JUST COMMENT ON THAT. CERTAINLY MR. [INDISCERNIBLE] MENTIONED A KEY WORD IN THE SERVICE OFFERINGS FROM AMAZON, IT'S HOW YOU ARCHITECT IT AND THAT GOES BACK TO, YOU KNOW IN THE ENTITIES THAT LOOK FOR SERVICES, YOU NEED TO MAKE SURE THAT YOU HAVE ADEQUATE ARCHITECTURE--FOLKS THAT ARE HIGHLY SKILLED IN CLOUD SOLUTIONS THAT KNOW HOW TO ARCHITECT, HOW TO ARCHITECT THE SOLUTION SUCH THAT THEY WORK FOR THE ORGANIZATION, HOW IT INTEGRATES WITH YOUR ORGANIZATION, THESE ARE FUNDAMENTAL ASPECT OF IT SO NUMBER ONE I WOULD JUST SAY THAT YOU KNOW JUDGE UTV REALLY SUPPORTING WHAT MR. SOUTH IS SAYING IS THAT YOU HAVE TO ARCHITECT IT WELL. IN ORDER TO GET THE BENEFITS THAT CAN BE OFFERED THROUGH THESE SERVICES. AND THAT'S NOT JUST IN TERMS OF MANAGING RISK, IT'S NOT JUST ARCHITECTURE BUT IT'S HOW YOU IMP LET IT AND HOW DOES IT INTEGRATE INTO YOUR ORGANIZATION, HOW IS IT ADMINISTERED, YOU KNOW BECAUSE YOU STILL HAVE RESPONSIBILITY AS THE ENTITY TO ADMINISTER THE RELATIONSHIP OR THE SERVICE. SO AGAIN IF I'M LOOKING AT A COMPANY, I'M LOOKING AT WHAT IS THEIR FRAMEWORK, WHAT IS THE FRAMEWORK THEY USE IN TERMS OF RESOURCES AND STANDARDS THAT THEY APPLY TO THOSE THIRD PARTIES AND HOW DO THEY MANAGE NOT ONLY ON A DAY-TO-DAY BASIS BUT HOW DO THEY VERIFY. THAT'S PROBABLY LOOKING AT AN ENTITY IS MAKING SURE THEY HAVE A VERY GOOD SOLID FOUNDATION THERE.

THIS WILL BE MY LAST QUESTION SO MY COLLEAGUE CANS ASK QUESTIONS BUT TO THAT POINT IS, IS THERE ANYTHING THAT WE AS THE COMMISSION SHOULD BE DOING THAT NERC SHOULD BE LOOKING AT, CIP STANDARD IN ORDER TO MAKE SURE THAT EVERYBODY THAT'S IN THE ENERGY INDUSTRY IS MEETING A MINIMUM STANDARD FOR TRYING TO GET THAT ARCHITECTURE TO MAKE THOSE PROCUREMENTS THAT MEET AT LATEST A MIN NUM STANDARD OR AT LEAST FORCE THEM TO THINK ABOUT IT, SHOULD WE BE DOING ANYTHING?

IF I CAN REAL QUICK, I THINK I HAVE TWO QUICK THOUGHTS. FIRST IS THE LARGE CSP LIKE US, WE'RE AUDITED ALMOST EVERY DAY OF THE YEAR BY THIRD PARTY AUDITORS, COMPANIES LIKE EASTERNEST AND YOUNG AND [INDISCERNIBLE]. AND SO THEY ARE NO REAL NEW CONTROLS OUT THERE. SO ALL THE CONTROLS WHETHER NIST, ISO, THEY'RE WORDED DIFFERENTLY BUT THEY EXIST AND WE'RE BEING AUDITED FOR THOSE ON A DAILY BASIS SO WE PROVIDE THOSE THIRD PARTY REPORTS TO OUR CUSTOMERS, SO YOU CAN ACTUALLY TRUST BUT VERIFY EVERYTHING WE SAY, CAN YOU SEE THE SPECIFIC CONTROLS THAT WE'VE IMPLEMENTED AND HOW WE'VE BEEN ASSESSED AGAINST THOSE CONTROLS. SO WHETHER IT'S AGAINST THE SOC TWO, A PCI, FED RAMP, UNDER THE FEDERAL, YOU CAN ACTUALLY SEE HOW WE'RE DOING AND HOW WE'RE ASSESSED. SO I THINK THERE'S AN OPPORTUNITY TO LEVERAGE THOSE EXISTING INDUSTRY AND INTERNATIONAL STANDARDS AND THOSE AUTOREPORTS AS A WAY TO TAKE A LACK AT WHAT CONTROLS YOU'RE INHERITING AND HOW WE ARE AND THE SECOND THING IS AS A CRITICAL INFRASTRUCTURE SECTIONAL ANALYSIS ARE ON, THE NIS CYBER SECHIITY FRAMEWORK WE HAVE A WHITE PAPER AND WE MAPPED OUR SERVICES TO THE VARIOUS SUBCATEGORIES OF THE CSF TO HELP OUR CUSTOMERS UNDERSTAND IF THEY USE THE CSF FOR THE ORGANIZATION AS A WHOLE SO THEY CAN SEE WHERE AWS SERVICES MAP IN AND HOW THEY CAN BE USED TO SUPPORT THOSE VARIOUS SUBCATEGORIES, SO NOW YOU DON'T HAVE TO LOOK AT THE CLOUD AS BEING SOMETHING SO UNIQUE AND DIFFERENT. YOU HAVE TO FIGURE OUT HOW TO MANAGE IT AND HOW IT FITS IN, WE CAN PROVIDE THAT MAPPING ALREADY FOR YOU AS WELL.

HI, I WOULD JUST LIKE TO ADD THAT I FEEL THAT WHEN YOU GO INTO--WHEN YOU LEVERAGE A CLOUD, YOU HAVE TO LOOK AT IT AS AN EXTENSION OF YOUR INFRASTRUCTURE YOU HAVE TO TAKE OWNERSHIP AND MANAGE THAT AND ECHO THAT INDUSTRY CAN LEVERAGE EXTERNAL CERTIFICATION AND CREDITTATION THOSE CONTROLS ARE IMPLEMENTED BUT ARE DIRECTLY RELATED TO OUR CIP REQUIREMENT. BUT BUT A DIRECT CLOUD ENVIRONMENT BUT THOSE DO TRANSLATE ACROSS THOSE DIFFERENT ESTIMATE THAD EXTERNAL ACCREDITATION.

I WANT TO SUPPORT THAT AND SAY WHERE CAN YOU HELP FERC OR NERC FROM AN ENDORSEMENT ACCREDITATION AND BE ABLE TO MOVE THAT ORDER IF MORE QUICKLY. WE KNOW FROM A RISK PERSPECTIVE OR I GUESS I SHOULD BACK UP AND SAY FROM A FINE PERSPECTIVE, THE REGISTERED *EPTITY IS ON THE HOOK FROM A CIP PERSPECTIVE AND THAT'S PRETTY PLAQUE AND WHITE AND I DON'T THINK YOU CAN DEFLECT OR PUT THAT RISK OVER ON TO THE CLOUD PROVIDER BUT 11 THING YOU CAN DO IS HELP US UNDERSTAND THAT THE CLOUD PROVIDER, DOES HAVE A GOOD RISK FRAMEWORK AND THEY'RE MANAGING TO THAT AND THEN THROUGH CONTRAST AND THINGS LIKE THAT, WE CAN HELP DRAW OUT SOME OF THAT LANGUAGE BUT I THINK THROUGH THE ENDORSEMENT, IT'LL REALLY GO A LONG WAY.

I WOULD JUST ADD TO THE GOOD DIALOGUE, I THINK ONE ALSO AREA OF FOCUS IS JUST AS WE LOOK AT ADVANCING OUR STANDARDS, IT'S REALLY ABOUT ENCOURAGING, BRINGING INDUSTRY TOGETHER, YOU KNOW UPDATING OR ENHANCING LANGUAGE WITH RESPECT TO THIS TECHNOLOGY, FOR EXAMPLE IF YOU LOOK AT THE EXISTING STANDARDS, YOUR INDIVIDUAL ATTENTION CAN GET DIFFICULT, ZERO, ZERO TWO, THE IN TERMS OF ASSET DEFINITION AND YOU KNOW HOW DO WE APPLY ELECTRONIC SECURITY PERIMETER TO A CLOUD IMPLEMENTATION HOW HOW ARE ALL THESE REEL KEEPSAKES STRAOBT A LOT OF IMPLEMENT--RELEVANT TO A LOT OF THIS IMPLEMENTATION TODAY. HOW DO WE HAVE THIS OTHER ASPECT OF TECHNOLOGY ENABLERS THAT WE'RE--YOU KNOW WE'RE POISED TO EMBRACE IN AN INCREASES MANNER SO JUST CREATING A PLATFORM FROM THAT DISCUSSION FOR OUR STANDARD SYSTEM ABOUT THE BEST THING WE CAN DO.

THANK YOU VERY MUCH. VERY INTERESTING DISCUSSION AND THIS IS NOT A TOPIC THAT I KNOW THAT MUCH ABOUT ALTHOUGH WE HAVE A LOT OF JOKES ON MY TEAM ABOUT WHAT KIND OF STUPID QUESTIONS WE CAN ASK ABOUT BACKING UP MY PHONE TO THE CLOUD BUT I HOPE I ADVANCED SLIGHTLY ON TO THAT. IT WAS INTERESTING HEARING THE ANSWERS TO QUESTIONS ON THE BENEFITS OF USING CLOUD VIRTUALIZATION AND ESPECIALLY MR. SOUTH'S EXPERIENCES AT THE CITY BECAUSE WE OBVIOUSLY DON'T WANT TO DEPRIVE PEOPLE WHO ARE RELY ON THE BULK ELECTRIC GRID OF GETTING THE LATEST TECHNOLOGY, THIS COMING UP THE FIVE G DISCUSSIONS THIS AFTERNOON. YET WE WANT TO MAKE SURE IT'S PROPERLY PROTECTED. THE STANDARDS AREN'T SUPPOSED TO BE THERE TO HINDER PEOPLE DOING THE BEST THING. SO I THINK I WILL START BY BORING IN A LITTLE MORE ON COMMISSIONENER MC NAMEE'S QUESTION, THIS IS THE SECOND YEAR IN A ROW THIS HAS COME UP AT THE TECH CONFERENCE. IF I REMEMBER CORRECTLY SPP BROUGHT IT UP LAST YEAR ISSUES THE NEED TO UPDATE STANDARDS FOR THE CLOUD BUT WE HAVEN'T GOTTEN ANY STANDARDS, FILINGS OR DIRECTED ANY CHANGES TO THE STANDARDS THAT I'M AWARE OF AND MR. ROSENTHAL IN YOUR PREFILE TESTIMONY, YOU SAID THERE'S A SAR DRAFTING TEAM WORKED ON CIP MODIFICATIONS, SHOULD WE EXPECT NOTHING TO BE COMING IN? I MEAN HOW DO WE BEST UNPACK THIS BECAUSE THEY WERE NOT PUT IN PLACE TO KEEP PEOPLE FROM DOING YOU KNOW WHAT'S BEST. HOW SHOULD WE FET FORMALLY INVOLVED? ONE OF YOU MENTIONED A WORKSHOP BUT THERE ARE STANDARDS THAT ARE RIGHT FOR UPDATES BUT WE HAVEN'T IDENTIFIED THEM? HOW DO WE GET THERE.

I WILL ADDRESS THAT I HAD THE HONOR OF CHAIRING THE TEAM LAST YEAR AND THE COMMISSION WAS PASSED ON THURSDAY AND WE HAD A SIX MONTH WINDOW THAT FERC GAVE US TO GET IT DONE AND HAVING THAT WINDOW, TIGHT SCHEDULE DROVE US TO DELIVER A GOOD QUALITY PRODUCT.

HAS THAT BEEN FILED WITH US NOW? THE YOU MEAN THE CIP-A?

YEAH.

IT WAS LAST WEEK.

SO THAT SIX MONTH WINDOW THAT CAME WITH THE FERC ORDER HELPED US A LOT. IT PUT A LOT OF ADDITIONAL PRESSURE ON US.

YOU'RE TALKING SUPPLY CHAIN, RIGHT?

NO, NO THIS, IS INCIDENT REPORTING.

I DON'T KNOW ALL THE NUMBERS.

I KNOW THAT THE--SO BUT THAT WAS ONE WE DIRECTED IN RESPONSE TO AN EARLIER FILING AND GAVE A DEADLINE. THIS ONE I DON'T KNOW IF THERE'S ANY DIRECTORS OUT THERE,.

THAT'S EXACTLY MY POINT SO RIGHT NOW WE HAVE ASAR, A REQUEST THAT'S ACTUALLY BEEN DRIVEN BY INDUSTRY AS OPPOSE THROUGH THE COMMISSION TO ACTUALLY DO SOMETHING AND IN THIS CASE, IT'S ABOUT UPDATING THE STANDARDS SO WE CAN PUT THAT CYBER SYSTEM INFORMATION OR THE CROWN JEWELS FOR A LOT OF INFORMATION IN THE WAY, IP ADDRESS, INFORMATION, NETWORK MAPS, IN THE INDUSTRY SO THE TEAM IS SPINNING UP RIGHT NOW, WE WILL START START OUR MEETINGS ALREADY WILL BE AUTHORIZED BY NERC IN THE TIME FRAME THEN A SIX-NINE MONTH TURN ROUND TO GET IT DONE. BUT ONE WAY WHERE YOU CAN HELP, I WOULD LIKE TO SEE THE COMMISSION DRIVE TOWARDS ENABLING CLOUD.

SO ISSUE A DIRECTIVE TO UPDATE STANDARDS?

CORRECT. CORRECT. I JOKE ABOUT IT, BUT AS I JOKE I KNEW I HAD TO CLEAN MY ROOM, BUT IT WASN'T UNTIL MY PARENTS TOLD ME, CLEAN YOU ROOM THAT I DID IT SO THAT CAN PUT IN URGENCY AND TIME BOXES SO WHAT'S IN FLIGHT MODERNIZATION, THOSE HAVE BEEN IN FLIGHT SINCE 2016 AND THAT'S A LONG PERIOD.

WELL THAT'S VERY HELPFUL AND YOUR ANSWER ALSO KIND OF TEASED OUT ANOTHER THING I WANTED TO ASK ABOUT THAT. A LOT OF-AND THIS IS CONSIST WENT THE DIRECTION THAT FERC IS GOING AND NERC IS GOING, A LOT OF OUR WORK IN THE GENERAL RELIABILITY AND SECURITY AREA IS INCREASINGLY RISK BASED AND PREMISED ON DIFFERENT FORMS OF RISK, SO IN THE CYBERSECURITY STANDARDS WE HAVE LOW, MEDIUM AND HIGH ASSETS, IN THE PHYSICAL SECURITY THERE WAS A TIERING OF THE MOST HIGH RISK SUBSTATIONS AND LOOKING AT PROTECTING DIFFERENT THINGS AT DIFFERENT LEVELS AND I'M WONDERING IF THAT TIERING OF RISK AND PROTECTION IS APPROPRIATE TO THIS AREA AND JUST KIND OF AICISM POLITIC ANALOGY LIKE WHEN YOU GET ON AN AIRPLANE, YOU WEAR YOUR DIAMOND RING OR WHATEVER ON YOUR BODY, YOU DON'T CHECK IT IN YOUR LUGGAGE, IF YOU HAVE MEDICATION YOUR FAMILY NEEDS IT'S LIKE IN YOUR CARRY ON BUT OTHER THINGS THAT YOU MIGHT VERY WELL NOT LIKE TO LOSE BECAUSE YOU WOULD HAVE A TERRIBLE VACATION IF YOU LOST THEM, YOU CHECK THEM BECAUSE THEY'RE LESS IMPORTANT. ARE THERE SOME THINGS JUST A MUCH SMALLER CATEGORY THAT SHOULD NOT GO TO THE CLOUD IN AND OTHER THINGS IT'S OKAY TO GO TO THE CLOUD? ARE ALL WE ULTIMATELY GETTING TO THE PLACE WHERE EVERYTHING WILL BE UP THERE AND THE KIND OF IDEA OF HAVING SOME THINGS YOU DON'T THAT YOU KEEP ONSITE IS MY WHOLE WORLD IN.

SURE I'LL ADDRESS THAT FIRST. AS YOU LOOK AT THE RISK WE REALLY DO NEED TO EVALUATE WHAT SHOULD GO TO THE CLOUD FIRST. SO AS I MENTIONED IN MY OPENING REMARKS, WE NEED TO BE VERY CAREFUL AND VERY DELIBERATE WHEN WE'RE ACTUALLY DOING THINGS LIKE SCEDA AND ENERGY MANAGEMENT TO THE CLOUD. THAT WILL TAKE TIME BEFORE WE CAN ACTUALLY TEASE OUT AND UNDERSTAND WHAT WHAT A GOOD SECURITY FRAMEWORK WILL LOOK LIKE AND AN OPERATIONAL FRAMEWORK WILL LOOK LIKE BUT THERE'S A LOT OF THINGS AS YOU LOOK AT THE DIFFERENT SERVICES THAT WE HAVE TO DO UP TO THAT LEVEL OF OPERATIONAL IS THAT RIGHT WE COULD MOVE TO THE CLOUD. SO I DON'T KNOW THAT I CALL IT LOW, MEDIUM HIGH, AS WE THINK OF IN CIP LANGUAGE BUT FROM A RISK PERSPECTIVE, THERE ARE THINGS WE SHOULD THINK ABOUT MOVING THERE AS QUICKLY AS WE DID.

SORRY. THANK YOU. I WOULD LIKE TO ADD TO THAT, THE WAY I HEARD THAT, THERE ARE THINGS THAT I ECHO, IT'S THE TIME NOW TO START THINKING ABOUT MOVING THE ECOMS OR PACS OR BEDS TO THE CLOUD, I THINK IT'S AN OPPORTUNITY BECAUSE THE OPPORTUNITY BY CLOUD PRODUCES SOME TYPE OF LATENCY FOR EXAMPLE, THAT COULD HAVE AN IMPACT TO THE SYSTEM. HOWEVER, I THINK THERE'S OPPORTUNITY TO LOOK AT THE MONITORING CAPABILITIES, THE UPON BEZ INFORMATION BECAUSE THE IMPACT OF LOSING INSIGHT INTO THAT INFORMATION IS NOT AS IMPACTFUL. SO I THINK THAT'S A GOOD STARTING AREA FOR US TO CONSIDER.

IS IT A VOLUMEETIC ISSUE AS PEOPLE GET MORE AND MORE BIG DATA WITH THEIR ADDITIONAL POINTS OF INFORMATION AND KPAOUPBICATION WITH THEIR CUSTOMERS THERINGLY BE MORE--OF A NEED TO RELY ON THESE TECHNOLOGIES OR?

YES DATA ANALYTIC SYSTEM MUCH SUITED FOR THE CLOUD AND TO ANSWER YOUR FIRST QUESTION, I DON'T THINK I WOULD WANT TO TAKE ANYTHING OFF THE TABLE RIGHT NOW. THE--PUTTING YOUR EMS IN THE CLOUD WOULD NOT BE MY FIRST CHOICE BUT FROM A PHASING PERSPECTIVE MOVING YOUR DATA YOUR BCSI THIS INTO THE CLOUD, YOU KNOW MOVING LONG-TERM PLANNING INTO THE CLOUD, LEARN, WITH THAT, AND THEN, MOVE ON TO YOUR PACS AND YOUR ECOMS AND YOU CAN SEE IT LAY OUT FROM A STRATEGY PERSPECTIVE BUT I WOULDN'T WANT TO TAKE ANYTHING OFF THE TABLE AT THIS POINT.

I THINK I WOULD PERHAPS ADD TO THE DISCUSSION FROM THE PERSPECTIVE THAT WHEN WE TALK ABOUT THE CLOUD SOLUTIONS AND OF COURSE IT'S A FAIRLY NEBULOUS TERM. I THINK WE NEED TO LOOK AT IT AS A TECHNOLOGY ENABLER, YOU KNOW TALKING ABOUT FIXED SERVERS OR MORE VIRTUALIZED SERVICERS AND/OR CLOUD TYPE SERVICES ISSUES THESE ARE JUST A TOOL THAT ALLOWS US TO ENABLE AND MANAGE TECHNOLOGY. THE QUESTION IS, IS WHAT INFORMATION IS RESIDING ON IT, WHAT IS THE FRAMEWORK BY WHICH WE MANAGE IT? SO I THINK THE KEY IS, STEPPING AWAY AND I'VE SEEN THIS EVOLVE OVER YEARS WHERE WE TEND TO GET FOCUS ON A CLOUD, WHAT WILL WORK AND WHAT WILL NOT AND WHAT WILL OR WHAT WON'T WORK IN THAT ENVIRONMENT IT TERMS OF WHAT DATA SHOULD OR SHOULD NOT GO, AND I THINK WE NEED TO STEP BACK AND LOOK AT A ANOTHER TECHNOLOGY. AND THE QUESTION IS ARE WE ADEQUATELY INSTRUMENTED TO MANAGE THAT TECHNOLOGY? ARE WE ADEQUATELY MANAGING THE RELATIONSHIPS THAT ARE INHERENTLY PART OF IT? SO THAT BEING ABOUTS KEY AND WHEN WE TALK ABOUT RISK, WHAT INFORMATION, WHAT IS THE OUTPUT, THE SERVICE, THE IMPACT IF WE LOSE IT OR IT'S EXPOSED, I THINK THAT BECOMES AN IMPORTANT PREMISE BY WHICH WE MANAGE FORWARD.

OBVIOUSLY THIS IS THE ELECTRIC GRID SO IT HAS SPECIAL IMPORTANCE BUT I THINK SOCIETY'S EXPECTATIONS AND UNDERSTANDING OF WHAT WE PUT ON THE INTERNET AND WHAT INFORMATION WE ALLOW TO BE SHARE INDEED THAT WAY HAS CHANGED SO DRAMATICALLY AND QUICKLY WHICH LEADS TO MY FINAL QUESTION, TO THE EXTENT, TO WHATEVER EXTENT THE MANDATORY RELIABILITY STANDARD, THE CIP STANDARDS ARE THE PROBLEM IN ANY WAY HAMPERING THE ELECTRIC INDUSTRY'S ABILITY TO FULLY UTILIZE CLOUD COMPUTING AND VIRTUALIZATION, THE NUCLEAR PLANTS AND THE HIGH VOLTAGE GRID ARE CRITICAL INFRASTRUCTURE THAT HAVE THOSE MANDATORY STANDARDS SO WHAT ARE OTHER CRITICAL INFRASTRUCTURES DOING IN TERMS OF CLOUD COMPUTING WHERE THEY DON'T HAVE THESE STANDARDS AND ARE THEY AHEAD OF ELECTRICITY, I MEAN, YOU KNOW WATER, GAS, FINANCIAL SERVICES AND BANKING AND HEALTHCARE, THERE'S ALL KINDS OF WAWE WOULD CONSIDER CRITICAL DATA OUT THERE. AND HAS THAT--THERE ARE THINGS WE CAN LEARN FROM THEM IN THIS AREA? IT'S NOT A REQUESTY FOR THE ELECTRIC COMPANY PEOPLE, SORRY.

I HAD A RECENT CONVERSATION WITH MY CIO AND HE WAS AT A ALL CIO MEETING IN PHILADELPHIA AND HE SAID HE WAS ONE OF FEW WHO DID NOT HAVE HIS MAIN APPLICATIONS IN THE CLOUD. HE WAS TALKING TO FINANCIAL INDUSTRY, AND THEY SAID, YOU KNOW WE DO TRILLIONS OF DOLLARS OF BANKING EVERY DAY IN THE CLOUD. YOU CAN MAKE IT WORK. YOU KNOW WAS THERE ADVICE. SO I BELIEVE, YOU KNOW WE CAN MAKE IT WORK, WE NEED TO BE CAREFUL, WE NEED TO BE JUDICIOUS, WE NEED TO PLAN BUT WE CAN MAKE IT WORK.

MAYBE LEARN FROM SOME OF THOSE?

SO ON THAT, WE'RE SEEING ALL CRITICAL INFRASTRUCTURES USING THE CLOUD IN SOME WAY SHAPE OR FORM. IN MY EXPERIENCE THE FINANCIAL SECTOR IS PROBABLY THE MOST MATURE AND ADVANCED SO WE HAVE BANKS AND PUBLIC RECORD ALREADY, CAPITAL ONE IS ALL OVER THE U.S., SO WHEN YOU LOOK AT BANKS AND THE FINANCIAL INSTITUTIONS, LIKE AT FINRA, WHAT THEIR GOVERNMENT MISSION IS, THEIR MOST CRITICAL APPLICATION IS IN THE AWS, YOU KNOW LOOKING FOR THAT FRAUD ACTIVITY WITHIN EXCHANGES. SO WE'RE SEEING ACROSS THE BOARD, AND IT GOES BACK TO MY POINT EARLIER, THERE'S NO UNIQUE CONTROLS, RIGHT? EVERYBODY'S GOING TO GO BACK TO THE SAME SECURITY CONTROLS, AND YOU'RE JUST LEVERAGING WHAT PEOPLE LEARNED TO LEVERAGE IN THAT AREA BUT WE'RE SEEING FROM HEALTHCARE, MANUFACTURING ACROSS THE BOARD. WE HAVE PARTNERS THAT HAVE DISTRIBUTED ENERGY RESOURCE MANAGEMENT AND DEMAND A RESPONSE SYSTEMS, ACTUALLY COMPLETELY BUILT AWS IS PROVIDING SYSTEMS TO UTILITIES CUSTOMERS SO I THINK IT'S A GREAT OPPORTUNITY TO LEVERAGE THOSE LESSONS LEARNED AND JUST APPLY WITHIN THE INDUSTRY.

THIS HAS BEEN REALLY HELPFUL. IT SOUNDS LIKE TWO SETS OF WORK, ONE IS THE STANDARDS AND HOW THEY NEED TO BE UPDATE BUD THE SECOND IS HOW WE MONITOR, AUDIT EVERYTHING ELSE, NOT REINVENTING THE WHEEL WHICH LEARNING FROM SOME OF THE PLACES WHERE THAT'S ALREADY HAPPENING. THANK YOU VERY MUCH.

JUST A HAVE COUPLE QUESTIONS FOR SOME THAT MIGHT HAVE BEEN ALREADY ASKED I WANT TO START TO MR. RESOURCESSEN THAT WILL BUT EXPAND TO OTHERS AS WELL, WONDER FIGURE THERE ARE TOOLS THAT ARE DEVELOPING TO EXAMINE THE IMPACT OF CLOUD COMPUTING BUT ALSO ON VIRTUALIZATIONOT GRID, ON THE RELIABILITY OF THE GRID AND THE SECHIITY OF THE GRID CAN YOU BE MORE SPECIFIC ABOUT TOOL WHEN IS YOU ASK THAT? I WANT TO MAKE SURE YOU ANSWER THE QUESTION CORRECTLY?

WELL, I GUESS PUT IT MORE SUCCINCTLY, HOW DO WE--FROM THE COMMISSION'S PERSPECTIVE AND NERC'S PERSPECTIVE AND EVERYBODY'S PERSPECTIVE, HOW DO WE IMPACT THE CLOUD COMPUTING AND PERSONALIZATION OF THE RELIABILITY OF THE GRID?

I HAVE TO THINK ABOUT THAT, ANYBODY ON THE PANEL HAVE ANY THOUGHTS?

ANYONE ELSE?

YEAH THAT'S--

JUST TRYING TO REFLECT ON THE QUESTION, YEAH, I THINK A LOT OF WHAT WE TALK ABOUT RELATIVE TO USE OF CLOUD AND SOME OF THE ENABLING CAPABILITIES IT BRINGS TO THE TABLE, I THINK IT'S REALLY NOT--IT'S INDOCTOR ECTOMYOSIN AND WHAT I MEAN BY THAT, WE HAVE TO MANAGE OUR ASSETS EFFECTIVELY, AND WE HAVE TO BE ABLE TO MAKE SURE THEY'RE OPTIMIZED AND OPERATING EFFECTIVELY AND CONTINUE TO RUN, WE UNDERSTAND WHERE THEY MAY BE LIKELY TO FAIL AND HOW DO WE--HEAR HOW ARE WE ABLE TO MANAGE THAT SO THAT THE RELIABILITY OF THE SERVICE WE PROVIDE TO THE YOU KNOW OUR CUSTOMERS REMAINS CONSISTENT. AND I THINK SO, LEVERAGING THE TYPES OF ANALYTICS KIND OF GOING BACK TO A COMMENT A MADE EARLIER, BEING ABLE TO DO THAT AND APPLY THAT TO HOW WE MANAGE THAT INFRASTRUCTURE HAS BEEN VALUABLE SO I DON'T KNOW IF THAT GETS QUITE TO THE QUESTION BUT I THINK IT GIVES US A VALUE STATEMENT TOWARDS HOW ARE WE MANAGING OUR OPERATIONAL SYSTEMS AND LEVERAGING THE TECHNOLOGY TO DO THAT.

I JUST WANT TO ADD--MR. JACOBS YOU TALK ABOUT VENDOR ACCREDITATION AND AND BEST PRACTICES AND SO ON, COULD YOU EWILL BEERATE ON WHAT THE GOVERNMENT CAN DO TO HELP PROVIDING WITH FED RAMP AND ALSO WHAT THE GOVERNMENT CAN DO IN TERMS OF VENDOR ACCREDITATION, WE TALK ABOUT IT EARLIER IN THE EARLIER PANEL FROM THE SUPPLY PERSPECTIVE, BUT SPECIFICALLY AS ITRIAALATES TO CLOUD AND VIRTUALIZATION AND THINGS THAT THE GOVERNMENT CAN DO THAT THEY'RE NOT DOING NOW?

SO I JUST WANT TO SAY, COME TO TO THIS INDUSTRY FROM THE DEPARTMENT OF DEFENSE WHERE I WAS A CONSULTANT WITH BOOZE ALLEN, FROM THE DEPARTMENT OF NAVY FOR THE LAST 11 AND HALF YEARS AND FED RAMP IS AN EXTERNAL ACCREDITATION THEY ENDORSE, I THINK ASHLEY CAN SPEAK TO THAT MORE BUT ALSO LEVERAGING THE CLOUD FOR THESE INSTANCES AS WELL, PRIVATE CLOUD FOR EXAMPLE, I THINK LEVERAGING EXTERNAL ACCREDITATION IS PROBABLY A GOOD PRACTICE IN TERMS OF UNDERSTANDING RISK ASSURANCE BECAUSE WHAT GOES INTO THAT IS ALMOST SIMILARLY TO WHAT HAPPENS FOR AN AUDIT, THAT ACCREDITATION IS DEPENDENT UPON IT AND AN INDEPENDENT AUDIT OF THEIR CONTROL IMPLEMENTATION. AND AT ANY GIVEN TIME THAT PROVIDER SHOULD BE ABLE TO GIVE YOU SOME ASSURANCE THAT THAT ENTITY HAS MET THOSE CONTROLS THAT ARE BEEN IMPLEMENT OFFICE OF DIVERSITY THAT SYSTEM AND HOW EFFECTIVE THEY ARE. THERE'S OTHER EXTERNAL, ACCREDITATIONS AS WELL, I KNOW WE ALSO HAVE A FIRM POLICY ON WHEN WE GO INTO THESE TYPES OF RELATIONSHIPS FOR OUR BUSINESS APPLICATIONS THAT ARE CLOUD PROVIDED, WE HAVE A STANDARD THAT WE LOOK AT THE SYSTEMS AND ORGANIZATIONS COMPLIANCE SOCK TWO TYPE TWO AND ALSO ANOTHER CERTIFICATION THAT IS INDEPENDENTLY AUDIT FOR THE CONTROLS ASK IMPLEMENTED AND THE EFFECTIVENESS OF THEM.

MR. SOUTH YOU MENTIONED THAT YOU'RE AUDITED PRACTICALLY ON A DAILY BASIS FROM ACCOUNTING FIRMS AND SO ON, IS THERE ANY ROLE FOR THE FEDERAL GOVERNMENT OR IS THAT JUST A PRIVATE SECTOR PERSPECTIVE THAT'S SUFFICIENT.

MY RECOMMENDATION IS TO LEVERAGE THE INDUSTRY'S AUDITS AND FRAMEWORKS SUCH AS A SOCK TWO VTI BECAUSE THEY'RE EFFECTIVELY DOING IT TODAY AND EVEN THOUGH THOUGH I SAY THAT BECAUSE WE HAVE OVER 80 INTERNATIONAL FRAMEWORKS AND STANDARDS WE'RE COMMRI WITH AND AUDITED TO, WE TRY TO LIMIT THE ACTUAL NUMBER OF AUDITS BECAUSE OF COURSE, YOU KNOW WE DON'T WANT, YOU KNOW A THOUSAND PEOPLE RUNNING THROUGHOR DATA CENTERS FOR AUDITS WHEN THEY'RE ALL LOOKING AT THE EXACT SAME THING, RIGHT? SO THAT'S WHERE THE THIRD PARTY SYSTEM IS REALLY THAT BEST PRACTICE WHERE YOU GET THE RESULT, YOU GET THAT ASSURANCE BUT WITHOUT US LOSING CONTROL AND SECURITY OF OUR DATA CENTERS.

MR. HAND DO HAVE YOU A COMMENT ON THAT WITH FED RAMP FOR THAT?

YES, THANK YOU SOY WANT WANT TO TOUCH ON THE PROCESS FOR CONTEXT, WE ARE KNOWN FOR CYBERSECURITY RIG OR AND THE STANDARDS THAT OUR VENDORS MEET, WE HAVE 156 VENDORS THAT HAVE FED RAMP AUTHORIZATION AND WE ARE FOCUSED ON BASE LINE FOR LOW INFORMATION MODERATE INFORMATION AND HIGH INFORMATION. AND SO, FOR INSTANCE, WE SEE ABOUT 80% OF OUR FED RAMP AUTHORIZED CLOUD SERVICE OFFERINGS ARE AT LEAST THAT MODERATE, AND JUST TO KIND OF DIVE A LITTLE DEEPER INTO THAT, THERE'S 325 UNIQUE SECURITY REQUIREMENTS, EVERYTHING FROM DISASTER RECOVERY AND CONTINGENCY PLANNING, INCIDENTS RESPONSE, ACCESS CONTROL, ENCRYPTION, ENREITERATING THAT CYBERSECURITY ASSOCIATE WIDE THIS, AS WELL AS A VERY COMPREHENSIVE AUDIT DONE BY THIRD PARTY ASSESSMENT ORGANIZATIONS NOOSATION, AND IN THAT AUDIT THEY LITERALLY GO THROUGH OVER THE MODERATE BASE LINE, 1200 DIFFERENT UNIQUE TEST CASES TO INSURE THAT HOW OUR VENDORS ARE SAYING THEY'RE COMMRIING WITH THESE, THAT THEY ARE, THROUGH INTERVIEWS AND EXAMINING INFORMATION BECAUSE IF GOVERNMENT IT'S IMPORTANT THAT BEFORE WE PUT OUR INFORMATION AND TECHNOLOGY, WE KNOW HOW IT'S BEING SECURED AND WHAT'S DOWN BUT NOT ONLY THAT THAT WE HAVE EVIDENCE RIGHT, THAT IT IS DONE THAT WAY AS WELL, SO THAT'S KIND OF THE PREMISE OF THIS AUTHORIZATION AND THE BEAUTY OF THAT WITH CLOUD AND I'M NOT SURE WITH THE COMMITTEE HERE AS DISCUSSED THIS PREVIOUSLY BUT WHEN I'M EIGHT GSA AND I'M USING A CLOUD PRODUCT AND THEN I HAVE FRIEND OVER HERE AT FERC USING THE SAME ONE OUR INFORMATION FOR THE MOST PART IS PROTECTED THE EXACT SAME WAY, RIGHT? SO THAT GIVES US THE ABILITY TO PRESCRIBE KIND OF ONE UNIFIED STANDARD TO THE VENDOR COMMUNITY TO ADHERE TO, TO TEST TO HAVE THOSE AUDITS AND TO BE VIGILANT AND SHOW US CONTINUING PROGRESS, CONTINUING TRANSPARENCY AND MAINTAINING THAT SECURITY POSTURE, AND THAT MEANT GSA I LOOK AT IT AND ISSUE SOMETHING FROM THE AUTHORITIES OPERATE AND MY FRIENDS AT FERC CAN ISSUE THE SAME AUTHORITY TO OPERATE AS WELL. SO IT GIVES THE VENDOR COMMUNITY A LOT OF TRANSPARENCY AND WHAT THE REQUIREMENTS ARE BUT ALSO IT'S DO ONCE USE MANY TIMES APPROACH THAT CREATES EFFICIENCY FROM A GOVERNMENT STANDPOINT IN WORKING WITH INDUSTRY, SO, YOU KNOW I KNOW THAT YOU ALL HAVE THE CIP, AND I KNOW THERE HAS BEEN EFFORTS TO CROSS WALK THAT WITH OUR FED RAMP BASE LINES, THERE COULD BE NEAT SYNERGYS THERE BETWEEN WHAT WE REQUIRE FROM A FED RAMP STANDPOINT THAT A LOT OF VENDORS ADHERE TO NOW TO WHAT THE CIP STANDARDS ARE REQUIRED AND I WANTED TO JUST SEE IF DAVID OR ANYONE ELSE ON THE PANEL HAD ANY FURTHER RESEARCH INTO THAT.

I WANTED TO SAY I REALLY LIKE WAASHLEY IS SAYING, I HEARD THE WORD TRANSPARENCY, THAT IS SO CRITICAL TO SUCCESS THE RELATIONSHIP BETWEEN, YOU KNOW THE REGISTEREDDENTITY AND THE CLOUD SERVICE PROVIDER AND THE AUDITOR IS ESSENTIAL, IT'S--WE HAVE TO MAKE SURE WE DON'T HAVE THAT WIZARD OF OZ SITUATION WHERE THERE'S SOMEBODY BEHIND THE CURTAIN AND IT'S JUST SAYING TRUST ME, SOMETHING'S HAPPENING AND I'M SURE YOU'LL LIKE IT. THERE HAS TO BE THAT RELATIONSHIP WHERE WE KNOW, YOU KNOW WHAT IS GOING ON, YOU KNOW WHETHER DAILY OR BUT VERY FREQUENT MONITORING AND ASSURANCE THAT OUR DATA IS SECURE, THAT THE SERVICE THAT WE PURCHASED, YOU KNOW IS AVAILABLE. THAT--THAT IS WHAT IS NECESSARY. WE AS A COMPANY HAVE EMBARKED ON MANAGED SERVICE PROVIDERS OVER THE YEARS ISSUES THE CONTRACT IS JUST THE BEGINNING AND YOU KNOW YOU--YOU DON'T WANT A CONTRACT TO FAIL BUT YOU HAVE TO GO INTO IT KNOWING THAT IT COULD AND SO YOU HAVE TO HAVE EVERYTHING IN PLACE YOU KNOW THAT FREQUENT MONITORING, THAT ASSURANCE ON A RECURRING BASIS TO KNOW. THE CONTROLS I,A GHEE ARE THE CONTROLS, ARE THE CONTROLS, THERE'S NO NIFTY CONTROL THATY GOING TO GIVE YOU MORE ASSURANCE BUT YOU NEED TO KNOW THOSE CONTROLS ARE OPERATING EFFECTIVELY ON A EFFECTIVE BASIS AND IF THEY'RE NOT, I WANT IMMEDIATE NOTICE AND I THINK ALSO IF YOU ARE GOING TO GET OUT OF THE CONTRAST, I WANT TO KNOW THAT MY DATA'S PUDGIERED. I DON'T WANT TO HAVE TO WORRY THAT IT'S OUT THERE FOREVER. YOU HEAR THE SAYING, ONCE IT'S OUT ON THE INTERNET, IT'S THERE FOREVER. WE HAVE TO KNOW THAT'S NOT THE CASE BECAUSE THEN WE'RE AT RISK FOREVER.

IF I COULD JUST ADD ONE ITEM TO THE CONVERSATION ON THAT, YOU KNOW I THINK THE ACCREDITATION GOING TO SOMETHING THAT IS KREBINIZED AS A SECURITY PRACTICE AND BEING ABLE TO MEASURE THESE SERVICE PROVIDERS AGAINST THAT, I THINK IS AN ESSENTIAL FOUNDATION. I THINK THAT'S IMPORTANT. IT'S WHAT I WOULD LIKE FOR IN TERMS OF IS THIS COMPANY WORKING WITH A COMPANY THAT HAS CULTURE AND A PRACTICE THAT REFLECTS THE KIND OF SECURITY POSTURE WE WANT TO SEE, BUT I WOULD ADD THOUGH, THAT AS WELL AS THE MAJOR ORGANIZATIONS NOOSATIONS CAN PROVIDE THESE SERVICES, IT STILL RELIES ON ME AS ANENTITY, YOU KNOW THEY CAN BUILD THE BEST HOUSE, THE MOST SECURE, DOORS, BUT WHEN THEY HAND ME THE KEYS DO I LOCK THE DOOR, DO I MANAGE THAT EFFECTIVELY AND SO THERE ARE TWO PARTS TO THAT EQUATION BUT I THINK THE FOUNDATION OF ACCREDITATION AND WHO AM I DOING BUSINESS WITH AND FUNDAMENTAL.

I CAN'T STRESS THE IMPORTANCE THAT MICHAEL JUST MENTIONED IN THAT THE CUSTOMER RESPONSIBILITY. SO IN MOVING TO THE CLOUD, THE CLOUD SERVICE PART WILL DO A LOT FROM A SECURITY PART, BUT THERE IS A DISTINCT ROLE AND LINE ITEM FOR THE AGENCY OR THE CUSTOMER IS STILL ON THE HOOK TO DO AND SO, WITH THIS FED RAMP PROCESS, WE MAKE SURE THAT OUR VENDORS, YOU KNOW DISCLOSE THAT TO CUSTOMERS, RIGHT? TO AGENCIES ON WHAT THAT SECURITY LINE ITEM IS THAT THE AGENCY IS STILL RESPONSIBLE FOR. SO RECOMMENDATION FROM MY END IS TO MAKE SURE THAT THOSE ARE ALSO, IF YOU ARE CONSIDERING MOVING TO THE CLOUD ESPECIALLY WITH THIS TYPE OF DATA MAKE SURE THAT THE CUSTOMER RESPONSIBILITIES ARE ALSO FLUSHED OUT BECAUSE YOU COULD INTRODUCE A LOT OF RISK OR YOU KNOW RISK TO YOUR ENVIRONMENT IF THAT'S NOT TAKEN CARE OF.

I WOULD LIKE TO ADD IF I COULD REAL QUICK TO THE ONE OF THE FIRST POINTS WHICH WAS WHEN YOU LOOK AT THE CIP LANGUAGE, A RECOMMENDATION IS ONE AT THE HIGHER LEVEL, KIND OF A START FROM THE DESIRED END STATE AND WORK YOUR WAY BACK TO THE DESIRED OBJECTIVES TO THE DESIRED CAPABILITIES TO MEET THOSE OBJECTIVES, TRY TO STAY CLEAR FOR TECHNICAL GUIDANCE AND THAT THERE'S AN OPPORTUNITY IF AND WHERE YOU NEED THAT TO MAP THAT TO FED RAMP BECAUSE THEY'RE ALREADY THERE. THEY ARE ADJUSTING AS NEED BE FOR THAT SPACE, SO THEN, THAT WAY, YOU'RE POETIC WILL SEE CANS STILL BE MET, SECURITY OBJECTIVES CAN STILL BE MET BUT THROUGH A MECHANISM THAT WILL BE EASIER TO BE MAINTAINED, AND ALSO TO THE POINT OF WHAT WE CALL THE SHARED RESPONSIBILITY MODEL AND THAT'S TRUE, IT'S TRUE TODAY IN YOUR ON ENVIRONMENT, AND YOU HAVE A EVERY TEAM TO MANAGE THEIR SECTION PROPERLY AND SECURITY PROPERLY AND THAT DOESN'T CHANGE WITH YOU. SO THERE IS THAT SHARED RESPONSIBILITY AND WE'RE CLEAR WITH THOSE SERVICES AND THEN WE PROVIDE THOSE SERVICES AND BEST PRACTICES AND GUIDANCE TO HELP OUR CUSTOMERS MEET THAT END OF THEIR RESPONSIBILITY MODEL FOR WHATEVER IT IS THEIR DESIRED SECURITY OUTCOME MUST BE.

JUST A FINISH UP, SOMEWHAT RELATED MATTER BUT IN YOUR TESTIMONY YOU TALK ABOUT A SARBANESOXLY TYPE OF APPROACH, DO YOU SEE THAT WORKING WITH THE NERC STANDARD REQUIREMENTS PROCESS.

RELIANCE ON AN EXISTING FRAMEWORK, VIA THE NIST OR SOMEONE MENTIONED EARLIER THE DNATF IS DEVELOPING CYBERSECURITY FOR SUPPLY CHAIN, LET'S FACE IT, GOING TO A CLOUD SUPPLY CHAIN MAY NOT BE COVERED BY CIP 13 NOW BUT FOR INITYS THAT WILL INCLUDE EVERYTHING IN THE CYBERSECURITY PLAN, IT WOULD ALREADY BE PART OF IT. I BELIEVE THAT THIS THE--THE CONTROLS ARE BAKED INTO THEIR PROCESS, MICHAEL SPOKE TO THAT CERTIFICATION, IS GIVEN, YOU GET THE THIRD PARTY ASSESSMENT TESTING THOSE CONTROLS AND THAT'S SIMILAR TO WHAT YOU GET WITH THE SARBANESOXLY, HAVE YOU GENERAL COMPUTER CONTROLS THAT ARE LOOKING TYPICALLY AT FINANCIAL CONTROLS IN THAT CASE.

THANK YOU, DOES STAFF HAVE ANY QUESTIONS?

THANK YOU COMMISSIONER MC NAMEE, AND I WILL LIKE TO FOLLOW UP ON I REQUESTY ASKED EARLIER AND THE QUESTION IS, YOU KNOW, ARE WE AWARE OF, IS ANYBODY AWARE OF ANY OTHER CRITICAL INFRASTRUCTURE INDUSTRY THAT ARE USING THE CLOUD AND HOW THEY'RE USING THE CLOUD? WHEN I THINK OF CRITICAL INFRASTRUCTURE, I'M THINK BEING WATER, WASTE WATER, NATURAL GAS, OIL PIPELINES, CHEMICAL PLANT PROCESSES? SO THE QUESTION IS, ARE THERE ANY OTHER CRITICAL INFRASTRUCTURE INDUSTRY INDUSTRIES USING THE CLOUD AND HOW ARE THEY USING THE CLOUD? AND SUBSEQUENT QUESTION WOULD BE ARE THEY USING THE CLOUD FOR CRITTAL PROCESSES? CRITICAL CONTROL PROCESSES? AND I GUESS I WILL START WITH--

SO THERE IS NOT ONE CRITICAL INFRASTRUCTURE INDUSTRY THAT WE DON'T HAVE CUSTOMERS IN USING AWI, TO THE EXTENT OF THAT I DON'T HAVE THAT INFORMATION FOR YOU, BUT I DO HAVE ONE CASE STUDY THAT'S ACTUALLY PUBLIC, ENO IN EUROPE IS US -ING OUR AWS CLOUD AND OUR IOT PLATFORM WHERE THEY'RE MONITORING AND INGESTING OVER METERING DATA AND INFORMATION FROM OVER 500,000 COMPONENTS OUT IN THE PARTICULAR TERRITORY IN EUROPE, BACK INTO AWS, SO THEY'RE USING IOT PLATFORM, BRINGING DATA IN AND DOING THE ANALYTICS IN THAT E-MAIL, SO THAT'S ONE PARTICULAR CASE STUDY FOR A RELATED INDUSTRY TO YOURS BUT WE HAVE CUSTOMERS ACROSS EVERY SECTOR THAT'S USING US IN SOME WAY SHAPE OR FORM.

OKAY, I JUST WANT TO SAY, I THINK IT'S A GREAT QUESTION, SOMETHING I DON'T THINK WE THOUGHT ABOUT BUT BEING LOOKING AT OTHER INDUSTRIES AND LOOK AT THEIR LOOED THATTARY PUTTING IN THE CLOUD TO MAKE SURE IT'S CRITICAL, BECAUSE RIGHT NOW WE HAVE A LOT OF SERVICES FOR MY CAN UMP THAT ARE IN THE CLOUD BUT THEY'RE NOT CRITTAL, RIGHT? WE ARE HOSTING WEB ENGINE, THINGS LIKE THAT, EXTERNAL WEBSITE, SO, YOU KNOW UNDERSTANDING WHAT OTHER CRITICAL INFRASTRUCTURE AND INDUSTRIES ARE DOING WOULD HELP KIND OF GUIDE AND SHAPE WHAT OUR NEXT STEPS WILL BE SO THAT'S SOMETHING THAT WE SHOULD DEFINITELY LOOK AT.

I KIND OF MENTIONED ALREADY IS LOOK AT CAPITAL ONE WHICH IS ALL KINDS OF INFORMATION IS THEY'RE ENTIRELY IN THE U.S., SO IT'S NOT JUST ONE MISSION CRITICAL SYSTEM, RIGHT? SO, WE DO HAVE AGAIN, I KNOW ABOUT PARTICULAR ENERGY SECTOR SECTORS AND SUBSECTORS BUT IN OTHER CRITICAL INFRASTRUCTURE, THEY HAVE THEIR MOST CRITICAL INFORMATION AND APPLICATIONS SERVICES IN AWS.

AND I WILL ADD JUST BASED ON THE EXPERIENCE WITH D.O.D., THE DEPARTMENT OF NAVY AND LEVERAGING CLOUD, I DON'T KNOW TO WHAT EXTENT IN TERMS OF CRITICAL. I KNOW THE WAY THEY LOOK AT RISK IS ALSO ENTIRELY DIFFERENT. THERE'S A CONVERSATION BETWEEN SECURITY ENGINEERING AND SYSTEM ENGINEERING AND THE IMPACTS OF FUNCTIONALITY IN THE WAY AND OUT OF DIFFERENT SECURITY CONTROLS AND IMPLEMENTATION, SO I KNOW IT'S A DIFFERENT PICTURE OF HOW THEY LOOK AT HIGH RECK AS WELL.

THANK AND YOU I JUST WANT TO SHARE BACKGROUND PERSPECTIVE TO MY OPINION AND THAT IS IN MY OWN PERSONAL OPINION, STORAGE OF DATA ON THE CLOUD IS FINE, STORAGE AND PROES ISING INFORMATION LONGER TERM IS FINE BUT AS YOU GOET TO REALTIME CONTROL PROCESSES, ABOUT QUALITY ABOUT USING THE CLOUD FOR THAT AND I HAD HEARD EARLIER, I THINK ONE OF PANELISTS INDICATED THEY MAY BE RECEPTIVE TO ACTUALLY USING THE CLOUD FOR SCADA TYPE APPLICATIONS AND CONTROL TYPE APPLICATIONS, I WOULD LIKE TO LEARN MORE ABOUT THAT I DON'T KNOW EXACTLY SURE WHO SAID THAT?

I'M NOT READY TO GO THERE TOMORROW. [LAUGHTER] , I THINK I PHRASED IT IN THAT I JUST WOULDN'T TAKE IT OFF THE TABLE TODAY. I THINK SOMETIMES AND MY CONCERN WITH THE CIP STANDARD SYSTEM THEY'RE WRITTEN APPROXIMATE--THEY LIMIT US AT TIMES AND THEY--I THINK DUE TO YOU KNOW WHERE THERE'S A FOCUS ON COMPLIANCE, LIKE HOW WILL I BE ASSESSED TO THIS AS WRITTEN AS OPPOSE TO HOW CAN I BE SECURE, IS THE STANDARD PROMOTING A TRUE SECURITY STANDARD OR IS IT TELLING ME HOW I HAVE TO DO SOMETHING, SO IT'S IN THAT VAIN THEY DON'T WANT TO TAKE--I'M JUST SAYING I DON'T WANT TO TAKE ANYTHING OFF THE TABLE TODAY, DO I SEE THAT HAPPENING IN FIVE YEARS? NO. TEN? I DON'T KNOW? BUT NOT TOMORROW.

AND I WANT TO ECHO WHAT BRENDA SAID. THAT I DON'T THINK WE'RE READY TODAY BUT WE DON'T WANT THE CIP REQUIREMENTS AND STANDARDS TO HINDER US FROM LOOKING AT THAT, I KNOW HOW LONG IT TAKES TO MAKE THOSE CHANGES. SO LET'S BE REALLY THOUGHTFUL AS WE GO THROUGH AND LOOK AT WHAT CLOUD LOOKS LIKE, WHEN YOU THINK ABOUT CLOUD THERE'S DIFFERENT DEPLOYMENT MODELS, PUBLIC, PRIVATE HYBRID, COMMUNITY, THINGS LIKE THAT THAT ACTUALLY OFFER DIFFERENT LEVELS OF PROTECTIONS AND THINGS LIKE THAT. SO AS WE LOOK AT STANDARDS LET'S FACTOR THAT IN AND NOT TAKE IT OFF THE TABLE BUT I DON'T THINK WE'RE READY.

I THINK THAT'S--I LIKE THAT APPROACH, WE ACKNOWLEDGE REQUIREMENTS SO WE HAVE LATENCY FOR TRANSFER AND TODAY THAT CAN'T BE MET HOWEVER WITHIN OUR DATA CENTERS IN THE REGION WE ACHIEVE MILLI SECOND LATENCY WITHIN OUR DATA CENTERS, SO WE'RE ABLE DO IT INTERNALLY TODAY, BUT THERE COULD BE A TIME IN THE FUTURE WHERE SOMETHING COMES AVAILABLE WHERE, THAT FOUR MILLI SECOND LATENCY COULD BE MET, RIGHT? SO I THINK BY AGAIN HAVING THOSE OBJECTIVES AND CAPABILITY RATHER THAN VERY PRESCRIPTIVE ETHICAL LIMITATIONS WOULD BE KEY IN THAT.

ALL RIGHT. THANK YOU VERY MUCH. I WANT TO ASK DAVE AND [INDISCERNIBLE] IF YOU HAVE ANY QUESTIONS?

IF YOU WILL INDULGE ME.

ABSOLUTELY.

THANKS ANDY, I WORKED IN ELECTRIC UTILITY FOR 24 YEARS AND ONE TECHNOLOGY ORGANIZATION I LEARNED IS WE ARE REALLY RISK AVERS, WE DON'T LIKE TAKING CHANCES. BRENDA I THINK YOU POINTED OUT THAT YOUR FOLKS WERE NOT LIKE EVERYONE ELSE IS AT THAT POINT AS FAR AS CLOUD COMPUTING I'M KIND OF CURIOUS AS TO SHOULD THE COMMISSION BE ENCOURAGING CLOUD COMPUTING THROUGH STANDARDIZATION, NOT THROUGH STANDARDS BUT THROUGH STANDARDIZATION OF WHAT WOULD BENEFIT THE INDUSTRY IN ITSELF?

WHAT I'VE SEEN SOMETIMES IS WHEN NEW STANDARDS ARE, YOU KNOW IN THE PROCESS OR AFTER THEIR APPROVED. THERE'S A LOT OF CONCERN OVER WHAT THE'S THE ENFORCEMENT DATE? HOW LONG IT WILL TAKE A COMPANY TO GET READY? AND SO I TRIED TO THINK WHAT WOULD HELP PEOPLE MOVE ALONG? MAYBE YOU COULD--THERED COULD BE MULTIPLE STANDARDS ENFORCEABLE AT THE SAME TIME. THERE MAY BE COMPANIES THAT WANT TO STAY ON VERSION FIVE AND SIX BECAUSE THEY DON'T WANT TO MOVE OFF--THEY WANT TO STAY ONPREMISE. THERE ARE'S OTHER COMPANIES THAT WANT TO MOVE QUICKLY. THEY COULD EARLY ADOPT A STANDARD. THEY DON'T HAVE TO WAIT FOR THE ENFORCEMENT PERIOD, SO THAT TO ME WOULD BE SOMETHING TO PURSUE.

YEAH, AND I THINK I'M REALLY MORE TOWARDS LIKE WHAT ARE THE THINGS THE INDUSTRY SHOULD BE LOOKING AT, THE ELECTRIC UTILITIES GAS AS FAR AS WHAT KIND OF INFORMATION SHOULD THEY BE RUNNING WITH AND UTILIZING ON CLOUD AS OPPOSE TO WHAT THEY'RE CURRENTLY DOING, IN OTHER WORDS ARE THERE BENEFITS TO INDUSTRY FOR SHARE THAGOREAN TYPE OF INFORMATION OR GETTING ON THE SAME PLATFORM?

I THINK KIND OF LIKE IT MAY BE SIMILAR TO THE CRISP PROGRAM BUT IF YOU HAVE A LOT OF DIFFERENT COMPANIES USING THE SAME CLOUD SERVICE PROVIDER AND YOU HAD SECURITY APPLIANCES DEPLOYED, YOU COULD ALMOST BE CROWD SOURCING CERTAIN TYPES OF INFORMATION AND THE POTENTIAL BREECH OR ATTACK OR DATA LOSS, IT COULD BE SEEN THAT YOU WOULDN'T SEE IT WHEN YOU'RE DOING YOUR OWN THING. I THINK THAT'S--I YOU KNOW I CAN'T SPEAK IN DETAIL ON THAT BUT IT'S SOMETHING WE'VE BEEN THINKING ABOUT INTERNALLY.

I'D LIKE TO ADDRESS THAT QUESTION BECAUSE I THINK IT'S AN INTERESTING ONE ABOUT WHETHER WE ENCOURAGE YOU PARTICULAR, WHETHER THE COMMISSION ENCOURAGES MAYBE A FOCUS ON THE TECHNOLOGY OR YOU KNOW MIGHT TAKE A BIT OF A DIFFERENT VIEW ON I THINK WHAT I THINK WOULD BE HELPFUL IS TO ENABLE INDUSTRY TO ADOPT WHAT WORKS FOR THEM. AND I THINK BY DOING THAT IS ALLOWING IN THE CONSTRUCT OF STANDARDS THE ABILITY TO EMBRACE WHERE IT MAKES SENSE A SOLUTION SET, A TECHNOLOGY SOLUTION SET. IT MAY OR MAY NOT BE A CLOUD IMPLEMENTATION SYSTEM BUT RIGHT NOW CAN YOU LOOK AT THE EXISTING STANDARDS AND SEE WHERE IT PROHIBITS US FROM DOING IT. AND WHERE IT PROHIBITS US THAT'S WHERE WE HAVE AN OPPORTUNITY FOR I THINK THE COMMISSION TO FOCUS ON CAN WE ENABLE IT, THEN IF YOU ENABLE IT THEN WE AS INDUSTRY CAN INNOVATE AND WORK WITH OUR PARTNERS TO MOVE FORWARD. RIGHT NOW WE ENTERTAIN THE CONVERSATION BECAUSE WE KNOW WE CAN'T COMMRI AND WE CAN'T PROVIDE EVIDENCE OF COMPLIANCE. SO THAT WOULD BE MY POSITION ON THAT.

GREAT. WELL ONCE AGAIN THANK YOU ALL. IT'S VERY IMPORTANT. I KNOW FOR ME SOMEWHERE TO COMMISSIONER LAFLEUR, I'M NOT ALWAYS MOST UPTO DATE ON TECHNOLOGY, HAVING MORE DETAIL AND YOUR EXPERTISE WAS HELPFUL. THANK YOU. WE WILL ADJOURN UNTIL 1:30 AND LOOK FORWARD TO SEEING EVERYBODY. [PROGRAM IS ON A LUNCH BREAK ] 5G.

--AND THERE'S OBVIOUSLY A NUMBER OF THESE ISSUES THAT HAVE BEEN ASHES RISING PARTICULARLY IN THE WEST BUT OBVIOUSLY THERE'S ISSUES THAT GO THROUGHOUT THE COUNTRY AND I APPRECIATE EACH OF YOU BEING HERE TO HELP ENLIGHTEN US ABOUT THAT, EXPLAIN WHAT'S HAPPENING, SOME OF THE CHALLENGES, MAYBE BEST PRACTICES AND WITH THAT WHY DON'T WE START?

GOOD AFTERNOON I'M [INDISCERNIBLE] I AM CURRENTLY SERVING AS DIRECTOR OF CORPORATION ENGINEERING SERVICES IN CALIFORNIA. SO FIRST OF ALL, THANK YOU. THANK YOU FOR HAVING US HERE. TODAY I REALLY WANT TO DISCUSS THREE ITEMS, FIRST I WOULD LIKE TO GIVE AN UPDATE WITH WHERE WE ARE TO THE 2020 ISOS, AS YOU ALL KNOW THAT'S JULY FIRST, COMING MONDAY, THE CALIFORNIA ISO WILL PROVIDE THE RELIABLE FUNCTION, [INDISCERNIBLE] FUNCTION AT THE CALIFORNIA ISO AS WELL AS [INDISCERNIBLE] NORTHERN CALIFORNIA AND WE'VE KIND OF CALL OURSELVES THE RC WEST FOR THIS PURPOSES. WE DID RECEIVE OUR CERTIFICATION, WE WENT THROUGH CERTIFICATION PROCESS WITH [INDISCERNIBLE], WE DID 34THS OF THE CERTIFICATIONS FOR SERVICE THROUGH YELL ONE. WE ARE READY AS A MATTER OF FACT WE PUT ALL OUR TOOLS UNDER PRODUCTION SYSTEMS, LAST WEEK AND EARLIER THIS WEEK ON MONDAY AND THAT'S PART OF THE REASON THEY ALLOW ME TO GO OUT OF OFFICE AND I'M HERE NOW BECAUSE WE'RE GOOD TO GO AND PRODUCTION SYSTEM AND TOOLS, EVERYTHING'S READY TO GO. AND ONCE THAT'S DONE, WE WILL EXTEND OUR SERVICE AREA FOR OUR FOOTPRINT TO BE OTHER [INDISCERNIBLE] IN THE WESTERN COB TPHEBGZS FOR NOVEMBER 1 AND THAT WOULD BE INCLUDE ABOUT 40 DA, 40 DOPS IN THE CONNECTION FOR NUMBER ONE. FOR THAT PARTICULAR PURPOSE WE ARE GOING THROUGH CERTIFICATION PROCESS WITH NERC AND WEC SO THERE'S A CERTIFICATION THAT'S COMING UP YELL 30TH IN THAT WEEK AND WE WILL START SHADOW OPERATIONS AS WELL IN THERE. AFTER THAT YOU NOVEMBER 1 TIME FRAME, PEAK RELIABLE--WHICH IS THE CURRENT RCS WILL TERMINATE OPERATION ON DECEMBER THIRD AND WE'RE ALSO GETTING READY AND WE WILL INSURE THAT WE WORKING IT WITH ALL OUR COLLEAGUES HERE TO MAKE SURE THAT WE'RE READY FOR RELIABLE OPERATIONS POST DECEMBER THIRD. WITH THAT WE'VE BEEN WORKING TOGETHER WITH SBP, [INDISCERNIBLE], BCRC, AS WELL AS [INDISCERNIBLE]. SO THE TWO TOPICS I WANT TO FOCUS TODAY IS TALKING ABOUT THE CURRENT THEMES ISSUE, COORDINATION AND WHAT NOT IN THE WESTERN CONNECTION. IN THE OPERATIONS PLANNING, REALTIME OPERATIONS, THE RC WEST, CURRENTLY, KNOWS THAT THIS IS A CHALLENGE THAT WE HAVE TO DO BUT WE DO KNOW THAT THERE'S A NEED FOR US TO EXCHANGE INFORMATION BEING TRANSPARENT AND THESE ARE INFORMATIONS THAT WE NEED FOR OPERATIONS PLANNING AND REALTIME OPERATIONS, SO INFORMATIONS WITH REGARD TO NETWORK MODEL, OUTREACH CORPORATION, THEY HAVE OPERATIONS PLANNING. THOSE ARE STUFF THAT WE WILL CONTINUE TO EXCHANGE AND WILL BUILD INFRASTRUCTURES TO EXCHANGE THAT INFORMATION IN THE ENVIRONMENT WE HAVE THIS MULTIPLE RCS IN THE WESTERN CONNECTION. WE HAVE ALSO ENTER INTO COORDINATION AGREEMENT RC WEST, CALIFORNIA ISOS THAT ENTER INTO THE COORDINATION AGREEMENTS WITH PEAK RELIABILITY, JULY 1 OPERATIONS. WE ALSO HAVE ENTERED COORDINATION AGREEMENT WITH ALBERTA WITH AESO, SO THAT'S ALSO DONE AND WE ARE CONTINUING AND WORKING CLOSELY WITH OUR RC COORDINATION AGREEMENT WITH SBP'S AS WELL IN THERE, SO WE DON'T EXPECT ANY ISSUES IN THEIR. WE DO KNOW THE IMPORTANCE OF HAVING AND WHAT NOT, AND FOR US, IT'S VERY IMPORTANT AND SO WITH THE USE OF TOOL WE BELIEVE THAT THAT WOULD BE REALLY GO AND AND IF [INDISCERNIBLE] AND EXPERIENCE AND WE WILL PERFORM ALL TASKS, RC WEST, WE REALLY BELIEVE THAT PEOPLE WOULD SUPPORT THE UTILIZATION OF THE WESTERN CONNECTION WITH THE GROWTH AND WE WOULD PROBABLY INVITE OTHER RCS THAT'S HOPERATING IN THE WEST TO HELP DEVELOP METRIC AND SHAPE PERFORMANCE FOR THE WESTERN CONNECTIONS AND WE WILL GO FROM THERE, SO THAT WILL CONCLUDE MY REMARKS AND LOOKING FORWARD TO OUR DISCUSSIONS LATER.

GOOD AFTERNOON. THANK YOU FOR THE OPPORTUNITY. I AM BRUCE [INDISCERNIBLE] I AM VICE PRESIDENT OPERATIONS FOR SOUTHWEST POWER POOL. SBP IS IN A POSITION LATER THIS YEAR WE'LL SERVE AS A RELIABILITY COORDINATOR IN THE EASTERN AND WESTERN INTERCONNECTION, SBP HAS BEEN SERVING AS AN RC IN THE EASTERN INTERCONNECTION SINCE 1997. A GEOGRAPHIC SERVICE TERRITORY HAS EXPANDED SEVEN-14 MIDWESTERN STATES DURING THE LAST TEN YEARS, RECENTLY 14 ENTITIES IN THE WESTERN CONNECTION HAVE CONTRACT WIDE SOUTHWEST PIE POLE TO PROVIDE SERVICES ON DECEMBER THIRD OF THIS YEAR. WE ALSO HAVE TWO DC TIES CONNECTING US WITH ERCOT AND [INDISCERNIBLE]. SBP PROVIDES COMMENTS ON OUR LONG-TERM OPERATIONAL EXPERIENCE IN THE EASTERN INTERCONNECTION AND ON PROSPECTERATION OVER THE PAST YEAR TO BEGIN TO PROVIDE RC SERVICES IN THE WEST. ABPS RC EXPERIENCE HAS SHOWN THAT COMMUNICATIONS AND DATA SHARING ARE KEY TO SUCCESSFUL COORDINATION WITH NEIGHBORING RCS. COMMUNICATION STARTS WITH IDENTIFYING OPERATIONAL CHARACTERISTICS IMPACTING BOTH RC AREAS. THIS LEADS TO RC-RC COORDINATION AGREEMENTS OR PLANS, JOINT OPERATING AGREEMENTS AND OTHER ARRANGEMENTS THAT PROVIDE FOR DIRECTION AND REALTIME OPERATIONS. DATA SHARING AND ESTABLISHING THE MECHANISM FOR THIS TO OCCUR, THE SUFFICIENTLY IS CRITICAL AS WELL. REALTIME OPERATIONS IDENTIFIES NOT ONLY IMPACTS IN OUR SYSTEM BUT ALLOWS US TO SEE THE CONDITIONS ON A NEIGHBORING RCS AND WHAT THEY'RE EXPERIENCING, WHICH ALLOWS SBP TO ASSIST AS APPROPRIATE AND AS WE CAN. OUR NEIGHBORS ARE VERY DIVERSE AND INCLUDES RTOS WITH OPERATING MARKETS AND MARKET BASE MANAGEMENT CONGESTION PRACTICES, RC THAT MONITORING A SINGLE BALANCING AUTHORITY AND RC THAT COVERS BALANCING AUTHORITIES WITH NO ORGANIZED MARKET, CONNECTED THROUGH DC TIES. --SEE SEE EACH RELIABILITY COORDINATE SEEING AS WE HAVE UNIQUE. --AND WHILE HAVING THESE JOAS AND AGREEMENTS IN PLACE WITH NEIGHBORS HAS PROVEN TO BE INSTRUMENTAL IN MAINTAINING LIABILITY, THERE'S ALWAYS ROOM FOR IMPROVEMENT. I'D LIKE TO HIGHLIGHT TWO PRIMARY SCENES, EFFORTS THAT WE BELIEVE WOULD BE ADDITIONAL VALUE TO CONSUMERS, THE FIRST IS ENHANCING COMMONALITY, SORE SAID ANOTHER WAY IMPROVING COORDINATION BY SPEAKING THE SAME LANGUAGE, WE'VE SEEN ENHANCED RELIABILITY WHEN WE WORK WITH OUR NEIGHBORS TO ESTABLISH COMMON WAYS OF DOING THINGS SUCH AS COMMUNICATING DURING EVENTS, THROUGH WORK WITH PJMOT INTERREGIONAL COORDINATION PROCESS OR MARKET TO MARKET PROCESS AND IN THE WAY WE COMMUNICATE AND COORDINATE OUTAGES ACROSS THE SCENE. WE BELIEVE IN EXTENDING THE SAME THING MATTERS SUCH AS DEFINITIONS OF EMERGENCIES, HAVING A COMMON UNDERSTANDING OF TRANSMISSION RATINGS AND ADVANCE OF THE A RELIABILITY EVENT AND IMPROVING INTERCONNECTION STUDIES ACROSS THE SCENE WOULD PRODUCE SIMILAR EFFICIENCIES AND ENHANCE RELIABILITY AND ULTIMATELY BEEN FIT CONSUMERS. THE SECOND ITEM THAT WE BELIEVE IN IS IMPORTANT IS MAXIMIZING USE OF TRANSMISSION AND GENERATION RESOURCES THAT WE HAVE. THE INEFFICIENT USE CAN RESULT IN DIMINISHED RELIABILITY AND COST TO CONSUMERS, MY EXPERIENCE AT PJM IS EFFICIENT AT MAXIMIZING THESE ASSETS. WE MAXIMIZE USE OF THE TRANSITION SYSTEM FOR ALL PARTIES BY BY ALLOWING--THE COMMISSION'S POLICY TO DRIVE DOWN BARRIERS TO TRADE RTSCS IS COMPLEMENTED BY SHARING UNUSED TRANSITION CAPACITY AND PROVIDING TRANSMISSION AT A LOWER COST AND REDUCING COSTS TO CONSUMERS. HOWEVER PHILOSOPHICAL DIFFERENCES IN HOW THEY DO A TRANSMISSION SYSTEM CAN CREATE EFFICS OF THE SAME, MEANT TO FULLY EMBRACE MARKETS IN THE TRANSMISSION SYSTEM WHILE OTHERS TAKE A MORE HISTORIC APPROACH FOR TRANSITION USAGE. INCLUDED IN MY REMARKS AND ANALOGY THAT CAN BE FOUND, BASED ON OUR HIGHWAY SYSTEM AND IN PARTICULAR SOME INTERSTATES REVIEWS AS A FRONT COST WHILE TAXPAYERS PAY FOR THE INTERSTATE FROM THE STATE, ANYONE CAN DRIVE ACROSS THAT INTERSTATE AT NO COST EVEN IF YOU'RE OUTSIDE OF THE STATE YOU PAID FOR IT IN, IN CONTRAST OTHER STATES AND TOLL-LIKE RECEPTOR ROADS WHILE ONE WAS DRIB ACROSS IT BY CONSIT TITUENCY, THE OTHER PAYS A TOLL, MISA BELIEVES THIS IS THE MOST BENEFIT TO CONSUMERS. NOT ONLY DOES IT MAXIMIZE EFFICIENCY AND USE OF EXISTING RESOURCES, IT ALLOWS US TO FOCUS ON HANDLING ISSUES AND EMERGENCIES RATHER THAN TRYING TO TRACK DOWN WHO DROVE ACROSS THE ROAD. THAT CAN CONCLUDES MY OPENING REMARKS AND I LOOK FORWARD TO ANSWERING QUESTIONS AND ENGAGING WITH THE PANEL. COMMISSIONERS GOOD AFTERNOON. JUST SO JUST A COUPLE BRIEF REMARKS BASED ON MY SUBCOMMITTED COMMENTS. I THINK THE NERC FORM A REALLY GOOD MINIMUM BASES FOR COORDINATION AMONGST NEIGHBORS AND FERC HAS LONG ENCOWERRAGED THE CREATION OF JOYMENT OPERATING AGREEMENT. IN FACT, I THINK BACK TO THE POST ALLIANCE RTO DAYS WHEN FERC SUGGESTED THE MISO PJMJOA AND I THINK THAT WAS CLOSE TO FEIGN YEARS AGO NOW. --FEIGN YEARS AGO NOW. THE DAYS OF THOSE PMJ WERE STRESSFUL BUT ONE THING I THINK I LEARNED FROM THAT IS ALL OF THOSE PROBLEMS ARE SOLVABLE. WE HAD A LOT OF VERY DIFFERENT REGIONAL THINGS WE HAD TO PUT TOGETHER INTO PRACTICES AND NOW WE HAVE A JOA THAT DOES TRUE REDISBATCH OF RESOURCES ACROSS THE BORDER WHENEVER THE RELIABILITY ISSUE IS AND WE TALK ABOUT THE ECONOMICS OF IT AFTER THE FACT AND I THINK THAT'S--I THINK THAT THAT'S A HEALTHY TEMPLATE FOR THE REST OF THE COORDINATING RELIABILITY COORDINATORS OR ISOTHAT IS HAVE TO WORK THROUGH THOSE PROBLEMS. WE HAVE FOUR DIFFERENT JOAS IN PJM, ONE IN NEW YORK, ONE WITH TBA AND THE CAROLINA COMPANIES, THEY ARE ALL DIFFERENT, SOME ARE VERY DETAILED, SOME ARE AT A HIGHER LEVEL AND THEY'RE JUST BASED ON THE REGIONAL DIFFERENCES AND ONE OF THE THINGS I THINK AN EXAMPLE WHERE THE NERC STANDARDS REQUIRE YOU HAVE EMERGENCY ENERGY AGREEMENTS WITH YOUR NEIGHBORS, ONE OF THE THINGS THAT JOA USED TO HAVE DONE IS MADE THAT I THINK A MUCH MORE IMPLEMENTABLE. WE'VE DONE THAT BEFORE BOTH WITH MISO AND PJM AND NEW YORK IN THE PAST, COMMISSIONER GLICK YOU MADE THE COMMENT ABOUT JOAS OR REGIONS SUPPORTING EACH OTHER IN EMERGENCIES AND I THINK THE JOAS THAT'S WHERE THEY'VE BECOME THE MOST USEFUL AND THEY'RE VERY GOOD IN EMERGENCY OPERATING GLOBALLYERATIONS OR OPERATORS DO THE RIGHT THING IN OPERATIONS AND WE HAVE PROCESSES IN PLACE TO FIGURE OUT THE ECCOMMICS AND EQUITY AFTER THE FACT SO I THINK THEY'RE A VERY GOOD EXAMPLE. ONE OF THE OTHER--ONE OF THE OTHER THINGS I THINK THAT'S IMPORTANT ABOUT THE SEAMS IS THAT THE COORDINATION OF THE DATA AND WHERE I SEE THAT PARTICULARLY IN THE FUTURE COMING IN IS AND I JUST LOOK AT NEW YORK STATE JUST ANNOUNCED VERY AGGRESSIVE RENUCLEOTIDESSABLE TARGETS AND THERE'S NO DOUBT IN MY MIND THAT THAT'S GOING TO HAVE AN IMPACT ON THE WAY PJM OPERATES IN THE FUTURE, BUT ONE THING I'M COMFORTABLE WITH IS WHEN I LOOK AT THE BASIS FOR OUR JOINT OPERATING AGREEMENT AND OUR DATA SHARING, I'M VERY COMFORTABLE, WE WILL BE ABLE TO GET TOGETHER, AND LOOK AT THE IMPACTS AND WORK WITH THE STATES TO BE ABLE TO OUT OW HERE GOING TO OPERATE THROUGH THAT. THE JOA'S CHANGE. I MEAN WE'RE FILING CHANGES TO THOSE ON A VERY ROUTINE, WE HAVE VERY ROUTINE PROCESSES FOR REVIEWING THEM AND IN FACT, TOMORROW, WE'RE FILING ADDITIONAL CHANGES TO THE JOINT OPERATING AGREEMENT TWEEZE PJM AND NEW YORK TO ACCOUNT FOR SITUATIONS THAT WE DIDN'T ENCOUNTER BEFORE. SO AND THIS IS SITUATIONS WHERE WE BUILD THE NEW UNIT AND IT CAUSES ISSUES IN NEW YORK AND THERE'S MAYBE PLANNING THINGS AND SO WE HAD THE--WE WILL FILE THOSE CHANGES BECAUSE WE HAVE THE OPPORTUNITY TO REVIEW AND MAKE CHANGES IN THE FUTURE. I THINK ONE THING THAT'S PROMISING ABOUT THAT IS THESE JOAS, I WILL NOT TRIBE THEM AS PERFECT BUT I THINK THEY'RE TIME TESTED AND THEY'RE VERY GOOD TEMPLATES TO BE USED THROUGHOUT THE INTERCONNECTION. AND I LOOK FORWARD TO THE DISCUSSION. THANK YOU.

GOOD AFTERNOON COMMISSIONERS, MY NAME IS ASHER STEED REPRESENTING BRITISH COLUMBIA HYDRO AND POWER AUTHORITY. THANK YOU FOR THE OPPORTUNITY TO CONTRIBUTE TO THIS TIMELY PANEL. I WOULD LIKE TO PROVOID A BIT OF BACKGROUND INCLUDING OUR CONTRIBUTIONS TO THE CONTINUED RELIABILITY OF INTERCONNECTIONS AS PEAK RC IS WINDING DOWN AND OUR OWN EFFORTS TO ESTABLISH THE RC FUNCTION AND THEN I WILL SHARE A PIRSPECTIVE AS WELL IN ADDRESSING SOME OF THE ISSUES ASSOCIATED WITH ESTABLISHING NEW RCS. JUST FOR SOME BACKGROUND BC HYDROIS THE LARGEST UTILITY IN WESTERN CANADA WITH 12,000 MEGAWALTS GENERATING CAPACITY, OVER 12,000 MINDING OF TRANSMISSION CIRCUIT AND SERVES OVER 4 MILLION PEOPLE. WE'RE RESPONSIBLE FOR PRUDENTIAL RESOURCE DEMAND BALANCING, AND TRANSMISSION SERVICE PROVIDER. WE'RE WELL CONNECTED TO BOTH THE U.S. AND ALBERTA, LONG HISTORY OF COORDINATION WITH OUR NEIGHBORS AND WE TAKE AN ACTIVE ROLE WITHIN INDUSTRY AT NERC, WEC AND THE NORTHWEST AS POWERFUL. THROUGHOUT 2018 WAS UNCERTAINTY SURROUNDING DRC FUNCTION, WE CONSIDERED OPTIONS THAT WERE AVAILABLE AND DETERMINED IT WAS IN THE BEST POSITION TO PROVIDE RC SERVICE FOR OUR PROVINCE AND IN LAST SEPTEMBER WE SUBMITTED OUR APPLICATION TO REGISTER AS RELIABILITY COORDINATOR. WE ARE WORKING TO INSURE WE HAVE THE CAPABILITIES IN PLACE TO SUPPORT THAT FUNCTION FOR OUR AREA AND ALSO TO EFFECTIVELY COORDINATE WITH THE OTHER RCS. OUR REGULATOR IS THE BCUC, BRITISH COLUMBIA UTILITY COMMISSION AND ORDERED TO UNDERGO CERTIFICATION FOR THE FUNCTION AND WEC LED THAT TEAM AND IT SHOULD BE IN THE BUCUC [INDISCERNIBLE] NEXT WEEK. TAKING A LOOK AT BACKGROUND, REALLY RC IN SOME FORM EXISTED IN THE WEST FOR OVER 20 YEARS AND PEAK'S OPERATION IN MY VIEW AND MANY SHARE THIS IS THAT IT REPRESENTS THE COLLECTIVE LEARN PREGNANT TWEPMENT OF INDUSTRY BEST PRACTICE THROUGHOUT NORTH AMERICA OVER THAT TIME. SO THERE IS STRONG RECOGNITION THAT MUCH OF WHAT HAS BEEN DEVELOPED BY PEAK AND OTHERS MUST CONTINUE IN SOME FORM TO SUPPORT RELIABILITY AND WE'VE HEARD SOME OF THAT FOR THE OTHER COMMENTS. SPECIFICALLY AROUND SEAM ISSUES SO BC HYDROIS ONE OF MANY PARTIES TRIBUTING TO ADDRESSING THESE ISSUES AND WE HAVE A LIST, WE GATHER OVER 50 SPECIFIC ITEMS THAT ARE BROADLY DIVIDED INTO THOSE ITEMS RESULTING FROM A NEW CREATION BETWEEN THOSE PARTIES AND THOSE ISSUES THAT THAT HAVE A BROADER IMPACT SUCH AS COMMON TOOLS AND PROCESSES. SO BRIEFLY SEAM'S AGREEMENTS WE HEARD ABOUT JOAS AND SEAMS AGREEMENTS FROM OTHERS, THIS REALLY IS THAT FOUNDATIONAL DOCUMENT THAT LAYS OUT THE OBLIGATION OF BOTH PARTIES, IN ADDITION THERE MAY BE SPECIFIC PROCEDURES BEYOND THAT PROVIDE INSTRUCTION FOR PERSONNEL TO COORDINATE OPERATIONAL ACTIVITIES. WE HEARD THAT PROCESS IS WELL UNDERWAY AND WE INTEND TO HAVE EXECUTED AGREEMENT SHORTLY WITH PEAK, ALBERTA AND RC WEST OR CALIFORNIA. WE HEARD ABOUT COMMON TOOLS REALLY IN THE WEST, THERE ARE A NUMBER OF COMMON TOOLS, THAT ARE CURRENTLY MANAGED BY PEAK AND WE WANT TO SEE THOSE CONTINUED, THESE INCLUDE THE WESTERN INTERCHANGE TOOL, ENHANCED CURTAILMENT AND THE SLIDE SYSTEM MODEL AND THE RC COORDINATION GROUP IS IN THE PROCESS OF DETERMINING HOW THOSE TOOLS WILL CARRY ON. AND WE EXPECT TO HAVE AN MOU OF SOME KIND WITH SUPPORTING FUNDING AND GOVERNANCE AND THEN LASTLY WIDE AREA COORDINATION IS SOMETHING THAT WE'LL ALL BE CHARGED WITH INSURING WE HAVE A WIDE AREA VIEW OF OUR OWN SYSTEMS AND THOSE BEYOND OUR SYSTEMS TO LOOK AT CURRENT STATUS AND COORDINATE PROPERTILY WITH THE JS AND RCS AND WE HEARD ABOUT VARIANTS REGIONALLY AND THAT'S SOMETHING WE'RE ALL ACTIVELY MONITORING. IN CLOSING REALLY WELCOME TODAY'S DISCUSSION AND I WOULD LIKE TO THANK YOU FOR THE OPPORTUNITY.

GOOD AFTERNOON COMMISSIONERS MY NAME IS JORDAN WHITE. I SERVE AS THE COMMISSIONER ON THE PUBLIC SERVICE COMMISSION BUT I'M HERE TODAY IN MY CAPACITY AS VICE CHAIR OF THE WESTERN INTERCONNECTION REGIONAL ADVISORY BODY, AS THE COMMISSION IS AWARE, WIRAB IS ESTABLISHED UNDER FEDERAL 215 J OF THE FEDERAL AND THE STATUTORY AUTHORITY SPEAKS WITH UNIT VOICE AND A PORTION OF MEXICO, AND WIRAB PROVIDES A UNIQUE AND VALUABLE AND IT'S COMPARABLE ENOUGH EVEN THOUGH AND AND THE FUTURE OF THE RELIABILITY COORDINATOR SERVICE OUTLIST, IN 2017, WIRAB COMMISSIONED A REPORT THAT OUTLINES THE METHOD TO OBJECTIVELY RESILIENCE VIEW AND ASSESS THE RELIABILITY AND COST IMPLICATIONS OF A TRANSITION FROM A NEARLY INTERNET CONNECTION WIDE RC WITH MULTIPLE RCS WITH SMALLER FOOT POINTS, THEY IDENTIFY THE TAOULS AND RELIABILITY BY PEAK RAOEUBLT AND MUST MEET TO SUCCESSFULLY FILL THEIR NEW ROLE. TODAY, WIRAB IS ACTIVELY OBSERVING THE TRANSITION AND CERTIFICATION A NEW RC IN THE WESTERN CONNECTION, I PERSONALLY HAVE THE OPPORTUNITY TO OBSERVE SEVERAL RC WEB OVERSIGHT COMMITTEE MEETINGS AND THE FORMS HELD AT THE WEB. THUS FAR I'VE BEEN IMPRESSED BY THE HIGH LEVEL OF PROFESSIONALISM AND DEDICATION OF THE PEAK STAFF AND THE ENGAGE OF THOUGHTFUL DISCUSSION AMONG PEAK AND RCS DURING THIS CRITICAL TRANSITION PERIOD. BECAUSE WIRAB'S FOCUS IS STRATEGIC POLICY DIRECTION, IT HAS ENCOURAGED THE NEW RCS TO STRIVE FOR EXCEPTIONAL PERFORMANCE ABOVE AND BEYOND COMPLIANCE WITH THE FERC RELIABILITY STANDARDS. AS I'M SURE YOU CAN APPRECIATE, COMPLIANCE AND EXCELLENCE ARE NOT ALSO SYNONYMOUS, WIRAB IS PLEASED THAT SOME OF THE TOOLS PEAK CREATED SUCH THE CALCULATOR AND THE *EURPT CONNECTION MEDDLE ARE EVALUATED BY THE NEW RCS, HOWEVER THERE'S ONE TOOL THAT RECEIVED LESS ATTENTION, NAMELY A PERFORMANCE SET OF METRICS THAT NOT ONLY MEASURED HOW WELL PEAK PERFORMED BUT THE CR FUNCTION BUT ALSO MEASURED THE QUALITY OF THE INFORMATION BEING PROVIDED BY THE BALANCING AUTHORITIES AND TRANSMISSION ROMERATORS. BY REVIEWING ENGINEERING OPERATIONS INFORMATION TECHNOLOGY AND OTHER PRACTICES, PEAK WAS ABLE TO MOVE BEYOND THE MINIMUM STANDARDS TO ENCOURAGE IMPROVED PERFORMANCE AMONG THE ENTITIES IN THE WEST. PEAK EMPHASIZE THAD HIGH QUALITY LOAD FORECASTING, OUTER SUBMITTALS WERE BOTH NECESSARY TO CONDUCT HIGH QUALITY NEXT DAY STUDIES AND TO PREPARE FOR REALTIME CONTINGENCIES. ULTIMATELY PEAK'S EFFORT RAISED THE LEVEL OF PERFORMANCE OF ALL OPERATIONAL ENTITIES IN THE WEST. WIRAB BELIEVE THAD ONGOING MONITORING AND PERFORMANCE IS CRITICAL TO MAINTAINING AND IMPROVING THE OVERALL LEVEL OF RELIABILITY IN THE WEST. WE UNDERSTAND FROM THE COMMENTS HEARD TODAY THAT RC WEST DEVELOPING A SET OF PERFORMANCE METRICS. WE APPLAUD THAT EFFORT AND RESPECTFULLY REQUEST THE COMMISSION AND ERO LEADERSHIP TO ENCOURAGE ALL RCS IN THE WEST TO ESTABLISH VOLUNTARY BEST PRACTICE PERFORMANCE METRICS SIMILAR TO THOSE DEVELOPED BY PEAK. CONSISTENT METRICS WOULD ALSO DEMONSTRATE WHETHER RELIABILITY DIMINISHED DURING THE MULTIRC TRANSMISSION, IF WIRAB'S REVIEW, THIS WOULD BE UNACCEPT FOR THE 83 MILL YEN PEOPLE LIVING ON THE WESTERN INTERCONNECTION WHO REQUIRE A RELIABLE BULK ELECTRICAL SYSTEM. I APPRECIATE THE FOCUS ON THIS IMPORTANT TOPIC AND LOOK FORWARD TO A PRODUCTIVE DIALOGUE THIS AFTERNOON.

THANK TO YOU EACH OF YOU FOR PROVIDING THOSE COMMENTS AND GETTING READY FOR THE QUESTIONS AND I WANT TO START OFF WITH TALKING ABOUT CC WEST AND WHAT AS BEEN SHADOWING AND HAVE YOU LEARNED ANYTHING? HAVE YOU LEARNED ANYTHING IN THE FIRST STAGE BY SHADOWING THAT--LESSONS LEARNED OR YOU'RE CONCERNED ABOUT AS YOU GO TO THE NEXT STAGE?

YEAH, SO WE REGULAR ME MEET WITH THE RCS AND MATTER OF FACT THIS QUESTION WAS ASKED ME TO AS WELL IN THE LAST MEETING THAT WE HAVE ABOUT THE LESSONS LEARNED AND I MENTIONED THAT FOR US IS THAT THERE IS THE USE OF A COMMON TOOL, RIGHT? THE USE OF COMMON TOOL, USE OF TRANSPARENCY OF THAT COMMON TOOL ALLOWED US TO BE ABLE TO REVIEW ACCURACY OF THE TOOL SO, CURRENTLY RIGHT NOW THERE IS PEAK THAT IS THE OFFICIAL RELIABLE DECODERS VERSUS RC WEST THAT IS SHADOWING, NOW WE HAVE A COMMON TOOL THAT HAD THE SAME THING NOW THAT WE ACTUALLY CAN DO AN ACCURACY CHECK WITHIN WHAT THE PEAK DOES AND WHAT THE CALIFORNIA [INDISCERNIBLE], WE FIND OURSELVES THAT HAVING TWO RCS IN THERE IS KIND OF BRING US TO A SITUATION WHERE IRON SHARPEN IRON. WE START ASKING WHY DID WE DO IT THIS WAY? WHY DID WE DO IT THIS WAY? IT CHALLENGE US, YOU KNOW THAT BECAUSE WE'VE BEEN DOING THIS FOR TEN YEARS BECAUSE THAT'S THE WAY WE'VE BEEN DOING IT AS OPPOSE TO MAKING A MORE PERFORMANCE IMPROVEMENT? SO A SPECIFIC EXAMPLE OF THAT IS WHAT MELISSA TALKED ABOUT THE USE OF COMMON RATING METHODOLOGY ACROSS TRANSMISSION OWNERS WHEN WE ASK THE QUESTION, OH THIS IS WHAT TRANSMISSION RATING WE USE AND WE SAID WELL, OKAY BUT BEE HAVE OTHER INFORMATION, THAT WE USE, IT'S UNCOVERED A LOT OF POTENTIAL EFFICIENCY AND POTENTIAL IMPROVE AS WE HAVE THIS MULTIPLE RC, SO I'M ACTUALLY EXCITED WHEN LOOKING FORWARD AND THE OTHER MULTIPLE RCS HERE TO BE ABLE TO CONTINUE THAT ENVIRONMENT WHERE WE COULD ACTUALLY CHALLENGE EACH OTHER AND BE ABLE TO WORK THESE OUT AHEAD OF TIME AND BE ABLE TO QUESTION EACH OTHER WITH REGARD TO GETTING BETTER, SO THAT'S ONE OF THE BIGGEST THINGS--BIG COMMON THING WHEN WE START HAVING THIS SHADOW OPERATIONS WHERE WE REALLY KIND SRO MULTIPLE RCS WITHIN PEAK AND CANNED WHAT.

UNDERSTOOD. NOW AM I CORRECT THAT WITH PEAK BEING DISSOLVED AND WITH THE NEW RCS COMING IN, WILL IT BE ALL ICS COMING OUT WEST?

SO RC WEST, ALBERT ABC HYDRO, AND [INDISCERNIBLE], YOU'RE CORRECT, FIVE.

SO YOU JUST SAID IN YOUR PREVIOUS ANSWER THAT THERE'S CERTAIN OPPORTUNITIES THAT FORCES YOU TO LOOK AT THINGS YOU WANT TO LOOK AT BEFORE. AND THIS IS FOR, YOU KNOW FOR ANYBODY WANTS TO JUMP IN BECAUSE OF THE EXPERIENCE YOU MAY HAVE HAD IN MISO AND PJM, BUT WHAT ARE THE THINGS YOU ARE LOOKING FOR AND WHAT SHOULD WE BE THINKING ABOUT AS WE'RE GOING TO A MULTISCENE AREA THAT JUST--WHAT KEEPS YOU UP AT NIGHT? MAYBE THAT'S A BETTER WAY.

LET ME START AND THEN I'LL SHARE WITH OTHERS. I WOULD REALLY LIKE--I HEAR THIS COMMENT IN THERE, THE DATA SHARING, THAT'S NUMBER ONE. THE OPENING AGREEMENT, THAT'S EITHER JOA OR COORDINATION OPERATING AGREEMENT THAT ALLOWS US TO HAVE A COMMON TOOL. I CAME FROM--SPEND A LOT OF MY TIME IN THE MIDWEST, SO I WAS IN THIS CONNECTION AND NOW I OWN THE WESTERN CONNECTION AND ALL THIS A LOT FOR A LONG TIME, BUT ONE OF THE THINGS THAT'S UNIQUE HERE IS THAT WE ACTUALLY HAVE A SET OF COMMON TOOLS AND UPON THAT SETS OF COMMON TOOLS ALLOW US TO ACTUALLY BE IN THE COMMON PLATFORM EVEN THOUGH THERE ARE MULTIPLE RCS BUT WE HAVE THE COMMON TOOLS THAT EVERYBODY SEE SYSTEM TRANSPARENT FOR EVERYBODY AND ALLOW US TO ACTUALLY OPERATE VERY EFFICIENTLY WITH THAT: SO--

YOU KNOW, I THINK FROM OUR INITIAL EXPERIENCE IS THAT WHILE CERTAINLY THERE ARE THINGS IN THE WEST THAT ARE DIFFERENT, THERE ARE SOME THINGS IN THE WEST THAT ARE THE SAME IN OPERATING THE EAST AS WELL AND ONE THING THAT WILL BE VERY IMPORTANT WITH MULTIPLE RCS AND THE GOOD COMMUNICATION, NOT ONLY PLANNING FOR THINGS ABOUT YOU IN REALTIME AND I THINK WHEN I LOOK BACK AT SOME OF THE THINGS WE EXPERIENCE IN THE EAST AND LIKE JANUARY 17TH'RE OF LAST YEAR, THE REALTIME OPERATORS WORKED WELL TOGETHER TO DO WHAT THEY COULD DO FOR THE SITUATION. WE THOUGHT WE HAD GOOD COMMUNICATION GOING INTO THAT EVENT AND WE REALIZE THAT WE CAN IMPROVE THAT AND WE MADE IMPROVEMENTS RIGHT AFTER THAT AND THE SAME THING HERE IN THE WEST. YOU KNOW? WE'LL PLAN FOR THE GOOD COMMUNICATION, YOU KNOW AND HOPEFULLY WE HAVE A PROCESS SET UP THAT WILL HANDLE ANYTHING AND WILL CERTAINLY BE ABLE TO WORK THROUGH ANYTHING THAT DOES COME UP AND THAT WE FACE, BUT YOU KNOW IT STARTS WITH THE COMMUNICATION SIDE. I THINK, YOU KNOW THE SECOND THING IN THE WEST IS OBVIOUSLY THE INTERCONNECTION WIDE VIEW THAT THEY DESIRE OR FOR US TO LOOK AT THE BROAD AREAS OF WESTERN INTERCONNECTION AND UNDERSTAND WHAT'S GOING ON IN OTHER PARTS THAT MIGHT EFFECT US AND YOU KNOW THAT IS VERY BENEFICIAL AND HELPS US APPRECIATE WHERE WE ARE WHICH WOULD BE THE ON THE EASTERN SIDE OF THE WEST OTHER THAN CONNECTION AND PRIMARILYOT SOUTHEST PART AND WHAT WE WOULD SEE, SO, YOU KNOW I THINK BOTH OF THE COMMUNICATION AND THE DATA SHARING, YOU KNOW SO FAR, I'M REALLY PLEASED WITH THE COMMUNICATION, AS I SAID BEFORE, PEAK IS DOING A GREAT JOB OF HELPING US IN THAT TRANSITION, YOU KNOW THE OTHER RCS THAT WE'RE PREPARING TO TAKE OVER HAVE BEEN GREAT IN COMMUNICATION. SO, I THINK I HAVE NOTHING BUT CONFIDENCE WE WILL BE ABLE ON DO THAT AND DO THAT EFFECTIVELY.

ONE OF THE THINGS THAT PJM AND MISO PUT THE J OA IN PLACE WAS A WRITTEN AND FILED LAWYER DOCUMENT AND ONE OF THE THINGS WE PUT IN VERY QUICK IS SOMETHING WE CALLED SAFE OPERATING MODE AND THE WHOLE IDEA OF SAFE OPERATING MODE IS THE OPERATORS HAD THE ABILITY IN AN EMERGING SITUATION TO DECLARE SAFE OPERATING MODE AND IF PJM WAS DECLARING IT, THE ISO WOULD RESPOND AND THEN WE WOULD GO BACK THAT ONE OF THE STRONGEST REQUIREMENTS IS THAT WE HAD TO FORMALLY COME UP WITH A DOCUMENT THAT LOOKEDDA THE LESSONS LEARNED AND WE WOULD USE THAT TO UPDATE THE JOA. BUT THE SAFE OPERATING MODE APPROXIMATE, WE DON'T USE IT NOW BUT WE HAD TO USE IT EARLY AND IT GAVE THEM THE CONFIDENCE THAT WE HAD TO USE IT IN A SAFE AND RELIABLE WAY THAT'S A TOOL THERE THAT WOULD OFFER UP TO THE NEW RELATIONSHIPS. GOOD COMMENTS AND A COUPLEEM THINK THISS I WOULD ADD SO WE TALKED ABOUT COMMON TOOLS, AND SO I THINK THAT'S IN TERMS OF WHAT KEEPS ME UP AT NIGHT. I THINK IT'S INSURING WE HAVE A GOOD STRONG FOUNDATION, EACH ENTITY AND AS MUCH AS THAT'S COMMON--COMMON WEST SLIDE MODEL, THERE'S OTHER ASPECTS, MODELING CONTINGENCIES, MODELING ACTION SCHEMES THAT EACH ENTITY HAS AS APPROPRIATE TO INSURE WEEKEND EFFECTIVELY COORDINATE TOGETHER. BEYOND COMMUNICATION, I THINK THAT'S SO IMPORTANT AND ACTUALLY SOMETHING I LIKE LAWN MOWER I'M SEEING RIGHT NOW IS TRAINING AND COORDINATION, SO WE'RE GOING THROUGH A PROCESS OF IDENTIFYING KEY ACTIVITIES THAT WE WANT TO DO SOME MOCK CABLE TALKS ON PRIOR TO OPERATING AND SO, SEEING THAT CARRY ON, SO I THINK AS MUCH AS YOU WANT TO BE PREPARED WHEN SOMETHING OCCURS, YOU WANT TO SET UP YOUR OPERATORS FOR SUCCESS BY HAVING PUT THEM THROUGH THEIR PACES PRIOR TO THAT ACTUALLY TAKING PLACE, SO THAT'S BEEN A GOOD EFFORT AND I THINK THAT'S SOMETHING THAT WILL BE IMPORTANT TO CONTINUE ON AS WE MOVE THROUGH THE NEXT YEAR OR SO.

I HAVE TWO MORE QUESTIONS. FIRST ONE IS MR. STEED, WE HAVE COMMON NERC STANDARDS AND ALL, BUT THIS IS YOUR OPPORTUNITY, IS THERE SOMETHING YOU ARE SEEING WITH YOUR REGULATOR WITH CANADA THAT WITH THE PRACTICE TO CANADA THAT WE SHOULD BE CONSIDERING?

IT'S A REALLY INTERESTING QUESTION. I GUESS, MAYBE FOR CONTEXT I WILL PROVIDE A SHORT SUMMARY OF WHAT HAPPENS WITHIN OUR PROVINCE. SO I TALKED ABOUT ENGAGEMENT AT UPON NERC/WEC, WE LIKE TO BE INVOLVED IN STANDARDS DEVELOPMENT AND THAT'S BEEN A KEY PIECE THAT'S BEEN IMPORTANT TO US FROM THE LEADERSHIP ON. WE'VE EXPRESS THAD TO OUR REGUTORS SO THEY UNDERSTAND WHAT'S INVOLVED IN STANDARDS DEVELOPMENT WE DON'T ADOPT IN THE SAME SCHEDULE THAT THE U.S. DOES, SO ONCE A STANDARD IS GONE THROUGH THE DEVELOPMENT AND APPROVAL PROCESS, IT'S CONSIDERED WITHIN OUR--WITHIN OUR JURISDICTION FOR IMPLEMENTATION, IN TERMS OF WHAT I THINK IS GOOD THERE, IS, AND WE HEARD ABOUT IT IN SOME OF THE EARLIER PANEL COMMENTS IS, THE CHALLENGE OF IMPLEMENTATION WITHIN A--YOU KNOW WHEN YOU'RE LOOKING AT ALL OF NORTH AMERICA, THERE IS SO MUCH DIVERSITY THERE, CAN IT CAN BE CHALLENGING TO ACCOUNT FOR THE DIFFERENCES IN A--IN A ESSENTIALLY A BLANKET APPROACH TO IMPLEMENTATION. SO I THINK THAT'S SOMETHING THAT I LIKE WHAT WE DO WITHIN OUR JURISDICTION IS WE GIVE OPPORTUNITY FOR ESSENTIALLY A SECOND LOOK AT A STANDARD. WE'VE GONE THROUGH THE DEVELOPMENT PROCESS AND THEN WE HAVE TO MAKE AN ASSESSMENT OF WHAT IT REALLY MEANS FROM AN IMPLEMENTATION STANDPOINT PRIOR TO BRINGING IT INTO EFFECT.

MY LAST QUESTION IS PROBABLY COMBINATION FOR [INDISCERNIBLE], THE DISCUSSION, I WAS STARTING TO HEAR THAT THE RELIABILITY ISSUE COMES FIRST AND THEN ABOUT EFFICIENCY AND COST COMES SECOND BUT CAN YOU ELABORATE MORE ABOUT HOW THOSE TWO THINGS INTERACT AND WHAT THE PROCESS IS, WHEN YOU'RE MAKING RELIABILITY DECISIONS FIRST AND THEN YOU WORRY ABOUT COST ALLOCATION OR COST ISSUES SECOND.

YEAH, I THINK WHAT WE BASICALLY DO IS LOOK AT THE SYSTEM AND USE EACH OTHER'S SYSTEM AS IT'S AVAILABLE, SO WE DEAL WITH THE MONEY LATER IS THE KEY, SO I DEAL WITH CONGESTION AND DEAL WITH THE ISSUES THAT MIGHT COME UP AFTER THE FACT AND YOU LET THE SYSTEM RUN AS IT IS SO YOU DON'T WORRY ABOUT WHO'S ON FLOWING ON WHO'S SYSTEM AT A PARTICULAR TIME, IF THERE BECOMES TO BE AN ISSUE, WITH MARKET, TO MARKET OR CONGESTION MANAGERS TO DEAL WITH THAT. SO IT'S JUST A MECHANISM, I THINK IT'S A COMMON UNDERSTANDING OF HOW WE OPERATE THE SYSTEM AND AN ABILITY TO SHARE BOTH, YOU KNOW TRANSMISSION AVAILABILITY SINCE IT'S SOMETHING THAT, YOU KNOW AND WE DON'T LOOK AT IT AS SOMETHING THAT WE HAVE TO CHARGE OR RESERVE IN ADVANCE. AND JUST TO ADD ON TO THAT, IT'S FUNDAMENTAL IN WHAT WE SET UP A VERY GOOD ROUTINE PRACTICE WHERE WE HAVE FLOW GATES ACROSS THE ALCOHOL SYSTEM AND THE WAY SAFE OPERATING MODE GOT USED A LOT IN THE INITIAL, IS THERE'S A FLOW GATE WE FORGOT TO COORDINATE AHEAD OF TIME AND NOW WHAT WE DO IS IN THE MONTHS LEADING UP TO THE REALTIME OPERATIONS WE IDENTIFY THOSE FLOW GATES, CRANK THEM BACK INTO THE MODEL THAT FIGURES OUT THE SETTLEMENTS SO IN REALTIME IF THAT FLIP, IF PYM RECEIVES THAT, WE BIND IN OUR EMS AND IT FLOWS THROUGH THE SETTLEMENT SYSTEMS SO ALL THAT IS NOW FIGURED OUT, BUT OCCASIONALLY OPERATORS WILL FIND SOMETHING THAT'S NOT ENVISIONED IN A FLOW GATE DEFINITION AND THEN AFTER THE FACT WE FIGURE OUT WHAT THAT IS PUT IT IN THE PROCESS.

WELL THANK YOU. THIS IS A REALLY INTERESTING PANEL. WELCOME TO ALL OF YOU. I ESPECIALLY WANT TO CALL OUT MR. STEED, I'M QUITE CERTAIN THAT EVERY RELIABILITY ANNUAL TECH CONFERENCE AND I WAS HERE FOR THE FIRST ONE WE'VE ALWAYS HAD SOMEONE FROM CANADA FROM THE GOVERNMENT OR PRIVATE SECTOR SO IT DOES REMIND US THAT THE N IN NERC STANDS FOR NORTH AMERICAN. SO THANK YOU. I WANT TO START WITH THE WEST. I FEEL LIKE I HAVE SO MUCH HISTORY WITH THE WHOLE SETTING UP PEAK AND BREAKING UP WEC AND ALL THAT. SO I THINK PEAK AND WEC AND I SEE MELANIE THE HEAD OF WEC IN THE AUDIENCE HAVE DONE A GREAT JOB SINCE THEY WERE SEPARATED AND BOTH OF THEM APPLYING THE LESSONS OF THE 2011 SOUTHWEST BLACK OUT WITH A WHOLE LONG LIST OF SITUATIONAL AWARENESS AND LEARNING ABOUT WHAT'S HAPPENING EVERYWHERE THAT'S BEEN VERY WELL APPLIED AND MY FIRST THOUGHT AND I THINK MY SECOND AND MY THIRD WHEN I HEARD ABOUT BREAKING UP PEAK WHICH ALSO RELATES TO DECISIONS THAT THIS COMMISSION MADE ON FUNDING AND ALL THAT BUT THAT'S ALL IN THE PAST NOW, WAS MAKING SURE WE SUSTAINED THOSE BENEFITS THAT PEAK AND WEC WORKED SO HARD TO GET. AND I THINK WE HEARD ABOUT SOME OF THEM, THE MODELING, MONITOR IDENTITY ARE ONING METRICS, I THINK I HEARD OTHER WORDS. SO, I KNOW IROL25 IF I HAVE IT RIGHT WAS FILED IN MAY. AND I THINK THAT REQUIRES THE--REGIONAL STANDARD TO REQUIRE THE USE OF SOME OF THE TOOLS BUT ARE THERE OTHER EITHER REGIONAL STANDARDS WE NEED OR THINGS THAT THIS COMMISSION HAS TO DO TO MAKE SURE THAT THE THINGS THAT WEC, THAT PEAK PUT IN PLACE GO FORWARD OR IS IT JUST A MATTER OF YOUR WORKING OUT THE MOU AND WE WILL OBSERVE AND KEEP AN EYE ON IT AND MAKE SURE THAT YOU KNOW IT'S ALL FINE AND JUST CHOOSE AN ANALOGY AND WHEN MICHAEL WAS TALKING ABOUT THE JOINT OPERATING AGREEMENT BETWEEN PJM AND MISO APPROXIMATE WE CALL THEM TOGETHER AND CHUNK HEADS A LOT OF TIMES TO GET IT AS SMOOTH AS IT IS NOW. IS THERE SOMETHING WE NEED TO DO OR HOW CAN WE HELP INSURE THAT THOSE TOOLS AND THINGS THAT PEAK PUT IN PLACE GET USED? WE WILL START WITH [INDISCERNIBLE] NOT HERE FROM THE ISO,--KIDDING! THAT'S WHAT I LEARN FRIDAY READING THE TESTIMONY. THAT WAS ONE OF THE MOST INTERESTING THINGS IN THE TESTIMONY, CALIFORNIA ISO HAS A NEW NAME.

RIGHT AND THEY DON'T GIVE ME A NEW CAR, [LAUGHTER] SO ANYWAY, BUT YOU'RITE. SO I'M ACTUALLY PART OF THE [INDISCERNIBLE] TEAM FOR THAT, SO THAT'S FINE. ONE OF THE THINGS IN THEIR DOMAIN PORTIONS IS ACTUALLY HAVE A COMMON METHODOLOGY FOR BOTH MODELING, AND MONITORING. SO, THERE ARE TWO THINGS IN THERE, SO METHODOLOGY OF MODELING AND METHODOLOGY AND THAT REQUIRES THE RCS TO WORK OFF FROM THIS COMMON MODEL THAT RC WEST WAS ACTUALLY DEVELOP FOR THE WHOLE WESTERN CONNECTION. SO THAT ALSO INCLUDES IN THERE, THE CONTINUING ANALYSIS OF SITUATIONAL AWARENESS AND BASIC LE THOSE ARE ITEMS THAT WE WANT TO MIC SURE WE DON'T MISS ANYTHING FROM THE SEPTEMBER 8TH EVENT AND LESSONS LEARNED THAT WE HAVE. INSIDE OF THAT REQUIREMENT IS ALSO THE REQUIREMENT FOR EXCHANGING AND USING THE DATA FOR OPERATIONS PLANNING FOR ALL THE OTHER STUFF. SO IN MY OPINION, I THINK THAT IS A VERY IMPORTANT DECISION THAT FERC WILL DECIDE ON THE [INDISCERNIBLE] AND THE NEW ONE AS WELL BASICALLY AND HAVE THAT IMPLEMENTATION DATE HOPEFULLY SOONER THAN LATER. AND WITH REGARDS TO THE AGREEMENT ITSELF WE ACTUALLY WORKED REALLY CLOSE WITH NEIGHBORS RCS. WE NEVER HAVE ANY PROBLEM WITH THIS. SO THE RC AND TO THE RC ACCORDINATION AGREEMENT, MOVINGA, AROUND WELL TO SUPPORT THIS DATA TRANSMISSION IN THERE. THE NERC STANDARD FOR THE IROTEN MANDATES US TO HAVE ALL DATA EXCHANGE FOR OUR REALTIME ASSESSMENT AND OPERATINGS ANALYSIS, SO WE BELIEVE THAT SUFFICIENT SORT OF DATA EXCHANGE AGREEMENT THAT WE'RE DOING AND THE COORDINATION WE'RE DOING THOSE SHAPE US TO ACTUALLY HAVE THIS SET OF COMMON TOOLS THAT YOU'VE HEARD. ASHERS MENTIONED THE FACT WE WILL HAVE A COST SHARING AGREEMENT WITH HOW WE FUND THIS TOOL.

THAT WAS VOLUNTARY? NO CONTRACT TO PAY.

CORRECT. CORRECT. SO THE RC WEST WOULD TAKE THE CONTRAST WITH THE VENDORS AND WE WOULD HAVE A IN, OARE U TO HAVE A CONTRACTURAL COST SHARING [INDISCERNIBLE].

FIRST OFF PEAK HAS DONE A GREAT JOB AND I THINK THAT'S RC AND WHAT THAT PROVIDES US AND DEDE ALLUDED TO THIS AND PEAK UNDERSTANDING WHAT THEY'RE DOING AND POTENTIALLY ENHANCE IT. SO THE MINIMUM I THINK WHAT WE'RE--WE WILL GET OUT OF THIS TRANSITION IS WHAT PEAK IS DOING IS POTENTIALLY IN CERTAIN AREAS IDENTIFY WAYS TO IMPROVE IT. , AS LONG AS THEY'RE CONSIST EPT RIGHT? BECAUSE YOU DON'T WANT TO IMPROVE IT ON ONE SIDE AND NOT THE OTHER SIDE. , ABSOLUTELY AND LIKE HE SAID, WE HAVE COMMON TOOLS FOR THE CRITICAL THINGS WE DO AND YOU KNOW US HAVING OPERATING EASTERN INTERNET CONNECTION, WE BRING THAT VIEW POINT OF WHAT WE'RE DOING IN THE EAST, WHAT ARE THEY DOING IN THE WEST AND WHAT'S A COMPARISON AND WHY ARE THEY DOING IT DIFFERENTLY IF THEY ARE DOING IT DIFFERENTLY WHAT'S BEEN FICIAL AND POTENTIALLY MAKE RECOMMENDATIONS TO SOMETHING THAT'S BEEN THOUGHT OF IN THE WEST. SO OVERALL IT'S A VERY POSITIVE AND I THINK WHAT YOU WOULD SEE IS THAT THIS WOULD BE A MINIMUM OF WHAT PEAK HAS AND FIND WAYS TO EPIANCE IT WHERE IT'S CURRENTLY AT.

MR. WHITE TALKED ABOUT METRICS AND I KNOW BRUCE, YOU SAID YOU'RE DEVELOPING METRICS, MAYBE THIS IS A DUMB QUESTION, BUT IS THERE ANY REASON WE CAN'T USE WHAT WE HAD, OR EVERYONE USE THEM FOR THEIR PIECE OR DO WE NEED TO REINVENT THEM?

SO FIRST LET ME CLARIFY ON THE METRICS, SO, UROLOGYST OPERATION STAFF HAS METRICS THAT THEY FOLLOW, SO WE LOOK @ THE END OF EVERY SHIFT, WE LOOK AT THE METRICS OF HOW THEY DID AND IT ALLOWS US TO COMPARE THE SIX DIFFERENT SHIFTS THAT OPERATE IN TERPS OF HOW EACH ONE IS HANDLING DIFFERENT SITUATIONS, SO WE HAVE THE METRICS THAT WE USE, YOU KNOW WE LOOKEDDA THE METRICS THAT COMMISSIONER WHITE REFERRED TO AND YOU KNOW THOSE WERE MORE OF A PUBLIC REPORT THAGOREAN THEY PUT OUT, AND YOU KNOW THAT'S SOMETHING THAT WE COULD DO, IF THAT'S REQUESTED, YOU KNOW WE LOOK AT THE METRICS AND FEEL LIKE WE'RE ALREADY PERFORMING THE MAJORITY OF THOSE METRICS SO IT WOULDN'T BE SOMETHING WE COULD PRODUCE AND PROVIDE AND BUT I FEEL LIKE WE'RE ALREADY DOING THE MAJORITY OF THOSE METRICS FROM OUR OPERATION OR PLAN.

I MEAN I DON'T WANT TO GET BELOW THE LEVEL I COULD EFFECTIVELY TALK ABOUT WITHOUT LOOKING AT THE METRICS BUT IT SOUNDS LIKE IT IT IS - I TRADE OFF BETWEEN THE CONSISTENCY OF THE PARTS OF SBP AND CONSISTENCY ACROSS THE FOUR OR FIVE RCS IN THE WESTERN INTERCONNECTION AND I WILL GIVE YOU A CHANCE.

I WAS GOING TO MENTION, I FIRST OF ALL WANT TO CLARIFY THAT YOU KNOW WIRAB ASKED US NOT ANOTHER STANDARD, AT THIS POINT WE'RE HOPING FOR A MANAGEMENT POSTURE TO STEP UP TO THE PLATE AND ELEVATE THE DISCUSSION ABOUT RELIABILITY OF WHAT'S YOUR INTERCONNECTION, ARE PEAK'S METRICS THE--YOU KNOW THE ABSOLUTE FUNDAMENTAL, YOU KNOW RIGHT WAY TO GO? NOT NECESSARILY. I DON'T THINK FROM OUR PERSPECTIVE, WE THINK THAT, WE THINK IT'S A GOOD STARTING PLACE.

THEY EXIST.

AND WE DO THINK THERE'S VALUE AND CONSISTENCY WE RECOGNIZE THAT THESE NEED FLEXIBILITY AND WHAT WE'RE REALLY LOOKING FOR AGAIN, IS DISCUSSION AND THIS IS A CONVERSATION STARTER, AMONG THE RCS ABOUT WHAT THE BEST PRACTICES ARE. I MEAN CERTAINLY OUR CANADIAN PARTNER VS PERSPECTIVES AND VALUE TO ADD IN THAT DISCUSSION, ET CETERA. SO THAT'S WHAT WE'RE LOOKING AT RIGHT NOW. NOT NECESSARILY ANOTHER LAYER OF POTENTIAL STANDARDS AND ENFORCEMENT, WE'RE TRYING TO FIGURE OUT WAY WAY TO POTENTIA WILY FIGURE OUT THAT POINT BUT IT'S FORDISCUSSION. AND THE TOPIC AND THE TEAM HAVE DONE A OUTSTANDING LEADERSHIP JOB, PROVIDING AS THE THING IS WITH TALENT TO WORK ON THIS TRANSITION, I WANT TO GIVE HIM A SHOUT OUT.

IF I CAN JUST HEAD ADD THE VALUE, I'M ON THE MAC OF THE PEAK AND THEY ARE DEDICATED A HUNDRED% ON DECEMBER 4TH I GUESS, YOU KNOW AND I'VE BEEN VERY IMPRESSED WITH IT, AND THE LEVEL OF PROFESSIONALISM AND GOING TO COMMUNICATE WITH THE OTHER RCS.

I WANT TO ASK A QUESTION THAT HOLDS ON THE WEST AND THE [INDISCERNIBLE] I'VE HAD THIS DEBATE WITH MARIE LIKE WHY DO HAVE YOU ONE RC AND YOU WE HAVE A WHOLE BUNCH OF THESE THAT SEEMS TO WORK AND IT SEEMS LIKE WE HAVE A TWO DIFFERENT THINGS GOING ON HERE AND THE WEST WE HAVE HAD ONE RC, AND NOW WE'RE DIVIDING IT INTO FOUR OR MAYBE FIVE IF IT STAYS IN PLACE, SEPARATE RCS, AND IN THE EAST, HAVE YOU ALL THESE SEPARATE RCS AND SEPARATE MARKETS AND YOU ARE WORKING ON YOUR SCENES TO WORK BETTER AND WHAT I HAD TROUBLE PARSING AS I WAS READING THE TESTIMONY AND LISTENING TO THE TESTIMONY, THE THINGS THAT WELL, MICHAEL AND MELISSA TALKED ABOUT AND MELISSA AND BRUCE ABOUT APPROXIMATE MARKET TO MARKET, HAVE YOU MARKETS YOU HAVE TRANSITION PLANNING, HOW MUCH OF THOSE ARE WHAT YOU DO TWO RCS WOULD DO AND HOW MUCH ARE HAVING TWO ADJACENT MARKETS AND TWO ASKWREUSENT MARKETS BECAUSE YOU'RE NOT GOING TO DO MARKET TO MARKET, I AM NOT SURE I COULD PALSZ A TEST ON WHAT IT IS BUT IT INVOLVES A MARKET AND SO, IT'S NOT GOING TO BE LIKE TWO RCS NEXT TO EACH OTHER AND TWO DIFFERENT COUNTRIES WILL DO MARKET TO MARKET SO HOW MUCH OF THAT IS APPLICABLE IS MY QUESTION?

I'LL TAKE THE FIRST SHOT AT THAT TOO AND I THINK IT'S A REALLY GOOD QUESTION BECAUSE WE HAVE FOUR DIFFERENT ORDERS AND WE HAVE FIVE DIFFERENT KINDS.

BAS AND RCS AND ALL OF THEM.

RIGHT, WE START OUT WITH THE FACT AND THE I DON'T FINISH IT CAME OUT OF THE FERC REQUIREMENT FOR THE FIRST J OA OR IF IT'S WHAT WE DEVELOPED BUT THE CHAPTERS ARE OUTLINED IN FUNCTIONAL AREAS AND THE FUNCTIONAL AREAS REALLY GOVERNED WHAT WE DID SO WE TOOK THE TEMPLATE FROM ISO AND WE WENT TO TBA AND SAID, WELL, WE DON'T HAVE TO WORRY ABOUT THE MARKET CHAPTER BUT HOW DO WE DO THESE THINGS, HOW DO WE DO THIS OUTAGE COORDINATION AND TRANSMISSION PLANNING OPERATIONS AND DADA THEA EXCHANGE AND ALL THOSE AND WE WENT TO NEW YORK, WE USE THE SAME OUTLINE AND HOW DO WE DO THAT AND WE WENT TO THE CAROLINAS, IT'S THE SAME THING, THEY'RE NOT APPLICABLE WHERE THEY ARE, BUT THE BASIC FUNCTION ARE COORDINATES, BECAUSE PJM FROM MY PERSPECTIVE AND OPERATIONS I LOVE THE FACT THAT I'M THE RC, THE BA AND THE COP, BUT I GET THAT THAT'S KIND OF UNUSUAL. IT MEANS KIUSE THE SAME TOOLS FOR EVERYTHING--

THAT'S WHAT ALL THE EASTERN MARKETS ARE, RIGHT?

VERY SIMILAR.

IN ISO ] SPEAKING AT SAME TIME ]

WE'RE JUST THE BA AND THE RC.

SO THEY'RE NOT A TOP, WHERE PJM IS? SO WE FIND A LOT OF SIMILARITIES.

THIS IS HOW COMPLICATED THIS IS, IT SHOULD BE FERC 101 THAT I'M LEARNING FROM.

THEY ARE THE RC, THE TOP AND THE VA BUT WE TRY TO MAKE IT DOWN TO FUNCTIONAL THINGS, THE FUNCTIONAL THINGS YOU HAVE TO DO AND THEN WE FIGURE OUT WHO DOES THEM, WHO HAS THAT RESPONSIBILITY.

AND I WILL JUST ECHO THOSE REMARKS, WE LIKE TO TAKE A TEMPLATE WE HAVE AT PJM AND APPLY IT TO ALL THE NEIGHBORS AND WE LOOK TO SEE, AND I HAD A REMARKS THERE WAS A TABLE IN THEIR FROM MISO THAT HAD ALL THE DIFFERENT AGREEMENTS AND IT WAS LIKE A MATRIX OF IS IT CONJUNCTION MANAGEMENT OR TRANSITION PLANNING BUT THOSE ARE THE THINGS THAT--

WITH A CHECK MARK AND THOSE ARE THE THINGS WE TRY TO TICK THROUGH TO SEE, WHAT DO WE NEED TO HAVE IN PLACE OF TBA WITH SOUTHERN COMPANY WITH FOLKS THAT AREN'T AND IT MIGHT NOT BE MARKET TO MARKET, IT PHOEUT BE CONGESTION MANAGESMENT, IT MIGHT BE NONMARKET TO MARKET, AND THOSE ARE THINGS WE LOOK AT THE IN THE FUTURE AND SO THERE'S OPPORTUNITY THERE EVEN IF YOU DON'T HAVE TO MARKET TO DO SOMETHING SIMILAR ACROSS THE BORDER. STH-RBGS I JUST AGREE WITH WHAT'S BEEN SAID, THE MARKET TO MARKET INTERACTION IS THE ESSENTIALLY THE ECONOMIC ASPECT OF THE RELIABILITY PART WHERE WE WOULD RELIEVE THAT ECONOMIC LOAMACYY AND IF YOU CAN'T DO THAT WE USE RELIABILITY COORDINATION TOOLS IN PLACE TO KEEP THAT CONGESTION LIVELY. SO IF WE HAVE A MARKET TO MARKET, WE CAN DO THAT, IF WE DON'T WE CAN USE THE FUNDAMENTALS OF RC TOOLS.

SAFE OPERATING MODE IS A RELIABILITY, I MEAN. MINAL QUESTION, IT'S KIND OF SMALL BUT KIND OF BEEN NAGGING AT ME. WHAT IS THE STATUS OF THE SEPARATE GROUP FORCE RC? HOW--I MEAN IS THAT--IT'S NOT CERTIFIED YET, SO IS THAT SOMETHING THAT I GUESS THAT WILL COME MAINLY TO YOU DEDE RIGHT? BECAUSE THAT'S IN THE MIDDLE OF YOUR RC AND I--SURE.

WE HAD THIS CONVERSATION SORT OF TO KEEP AN EYE ON.

RIGHT AND I'LL ADD TO THAT. WE HAVE BEEN WORKING WITH FORCE AND THE RCS OF PROCESS, AND OUR BEDDING SAN FRANCISCO GREAT AND THERE, CERTIFICATION AND PACK PAG AND THEY ARE GOING THROUGH AND AND TARGET DATE, AND THE 34THS OF THE CERTIFICATION--SORRY NOT THE OPERATION ACTUALLY THE SAME DATE OF THE PEAK FOR DECEMBER 30. SO AND WE HAVE MULTILE VA BUT THE GRID FORCE VA ITSELF AND RIGHT NOW IT IS PART OF THAT CERTIFICATION FOR THE RC. AND AND BY THE RCCOMPANIES BUT MAYBE I'M WRONG, I SHOULD GET MY MATH BUT--

SO SOME OF THE GRID FORCE P AS, A COUPLE THEM WILL BE IN ALL RC, AND THEN THERE'S THOSE THAT WILL BE THERE OWN RC AND THOSE ARE IN WASHINGTON.

CORRECT. SO GRID FORCE HAVE FOUR, GRID FORCE ENERGY AND MANAGEMENT SERVICE, I THINK THAT'S A COMPANY NAME, THE GRID FORCE COMPANY ACTUALLY HAVE AT LATEST I BELIEVE IT'S FOUR DIFFERENT VA WITHIN THAT, TWO OF THEM'S GOING WITH BRUCE AND TWO OF THEM OR ACTUALLY ONE OR TWO OF THEM WILL GO ITS OWN RC.

WELL GRID FORCE IS FOR ITSELF AND I WOULD URGE THAT ALTHOUGH IT LOOKS SMALL ON A MAP, THERE BE A LOT OF ATTENTION TO THAT THEME OR WHATEVER, IT'S LIKE THERE'S ONE BIG SCENE RIGHT BECAUSE THERE ARE A LITTLE MUNCH KINS AND DOES THAT TRANSLATE TO OTHER PEOPLE SAY MUNCH KINS OR IS THAT A NEW ENGLAND THING?

I WAS GOING TO SAY YOU'RE CLEARLY FROM BOSTON.

BUT DUNKIN' DO NUT SYSTEM EVERYWHERE NOW.

I AM STARTING TO GET HUNGRY NOW, SO I WANT TO START WITH THE WEST AS WELL AND MOVE ON TO THE OTHER TO INTERCONNECT BUT I WANT TO KIND OF PICK UP FOR COMMISSIONER LAFLEUR, BUT SO SHE POINTED OUT THAT THE WEST OBVIOUSLY UP UNTIL NOW HAD ONE RC AND THE BUNCH OF DIFFERENT RCS IN THE INTERCONNECT, BUT I UNDERSTAND WHY AFTER PEAK WAS BREAKING UP AND SOME PEOPLE WENT SOME SOME PEOPLE DIDN'T WANT TO GO WITH CALIFORNIA, OTHERS WANTED TO DO THINGS DIFFERENTLY SO THAT'S WHY WE HAVE UP TO FIVE RCS COMING UP BUT ISN'T IT--I KNOW WE DON'T HAVE CONTROL OVER THIS BUT ISN'T IT JUST INCREASING THE RISK O HAVE ALL THESE AGREEMENTS AND DO EVERYTHING PROPERLY, ISN'T IT BET FERRANDIS A PERSPECTIVE TO HAVE ONE RC IN THE WEST?

I'LL ADD ON THAT.

SO MY PERSPECTIVE ON EVERYTHING IS THEY'RE [INDISCERNIBLE], IF YOU LOOK @ SINGLE RC, THE PRO IS YOU DON'T HAVE COMMUNICATION, YOU DON'T HAVE A SEAM, YOU DON'T HAVE THE ABILITY TO LOOK AT IT ALL ON YOUR OWN, BUT I THINK THE CONS ARE SOME OF THE THINGS WE TALKED ABOUT. ONE IS THAT WITH MULTIPLE RCS YOU HAVE MULTIPEL EYES LOOKINGA THE IT, IT GIVES YOU OPPORTUNITY TO ASK THE QUESTION OF THE NEIGHBOR, WHAT ARE YOU DOING ABOUT THIS? THIS LOOKS A LITTLE RISKY OR THIS LOOKS LIKE IT MIGHT CHALLENGE RELIABILITY. I THINK THAT'S A BENEFIT YOU GET FROM MULTIPLE RCS. ANOTHER THING I WILL BREAKUP AS AN EXAMPLE I WILL BREAKUP 2017 AND 18 THAT WAS A WIDE AREA ISSUE AND AND WE HEAD OVER TO THAT EFFECT, SO ONE RC THAT WOULD HAVE BEEN REALLY CHALLENGING TO HAVE THE RESOURCES IN THE ABILITY TO MANAGE WIDE SPREAD PROBLEM AREA. VALUE AND THE RCS AND BEING ABLE TO HAVE THAT CONVERSATION AND OFF EACH OTHER AND JUST BY EXPERIENCE, I CAME FROM MIDWEST AND BACK THEN, YOU KNOW, MIDWEST MIGHT--IS A BIG FOOTPRINT AND WE HAVE ONE-TWO AND WHAT NOT THEY HAVE MULTIPLE CONTROL CENTER, WE HAVE 80 PEOPLE YOU KNOW IT'S HUGE, AT THE END OF THE DAY, WHEN I MOVE TO WEST OTHER THAN CONNECTION, I LOOK AT PEAK, IT'S GREAT, ONE BIG THING, AND SEPTEMBER 8TH, AND WE TALK ABOUT THE FACT THAT'S STAFFING PEOPLE AT THE END OF THE DAY WHEN WE GET INTO EMERGENCY THERE, 'S A LIMIT ON HOW 8 PERCENT OR 2 PERCENT CAN DO, BUT THERE'S BENEFIT OF HAVING THE COMMON TOOL IN ALL OF THE STUFF. SO MOVING FORWARD WHAT I'M HOPING, WHAT WE'RE TRYING TO ACHIEVE IS THE COMMON TOOL SAME SET OF TOOLS BUT THEN WE HAVE MORE PEOPLE THAT WAY WE COULD ACTUALLY HAVE THE BENEFIT OF BOTH ENVIRONMENT WHERE WE EACH RC IN THE WEST HAVE THE SAME COMMON TOOL, HAVE THE SAME EYES TO BE BE ABLE TO SEE IT BUT THEN NOW WEB CONNECTED HAVE MORE EYES TO DOUBLE CHECK AND SECOND GUESS, NOT SECOND GUESS, NOT GOOD BUT CHALLENGE OURSELVES AND ASK THE QUESTION, ARE YOU SEEING WHAT WE'RE SEEING, SOPHISTICATEDY THAT'S WHAT WE'RE AFTER IS USING THE COMMON TOOL BUT HAVING MULTIPLE EYES TO ACTUALLY LOOK AT IT.

COMMISSIONER WHITE DO HAVE YOU A COMMENT?

I WOULD SAY YOUR POINT IS WELL TAKEN, MOVING FROM THE PEAK, FROM MY PERSPECTIVE I GUESS I WOULD SAY, YOU KNOW ONCE THE DECISION WAS MADE, WE HAD TO DID THE STAGES OF GRIEVING QUICK AND FOCUS ON THE FUTURE. THE FACT OF THE MATTER IS THAT ON DECEMBER 4TH THERE'S NO GOING BACK, THERE WILL NO LONGER BE OPERATIONAL AND SO, WE'RE CLOSELY MONITORING IT. WE HAVE A HIGH LEVEL OF CONFIDENCE BUT NICK BROWN ASKED WE'RE AT THE CRITICAL STATION, IT'S MISSION CRITICAL FOR THE RCS JUST FOR COMMUNICATION, COMMUNICATION, COMMUNICATION, SO THAT'S ALL WE CAN DO AND I DON'T KNOW BEYOND THAT WHAT I CAN SAY.

I UNDERSTAND THERE ARE THREE--I THINK THERE ARE THREE RESERVE SHARING GROUPS WITHIN THE WEC NOW, DOES ANYONE KNOW IF THERE ARE GOING TO BE ANY SITUATIONS WHERE A RESERVE SHARING GROUP WILL BE SOME AND SBP WEST AND SOME--

YES.

YES.

GIVEN THAT IS THERE--WHAT KIND OF RELATIONSHIP, WHAT KIND OF AGREEMENTS ARE IN PLACE TO DEAL WITH REAL TYPE OPERATIONS OF THOSE MEMBERS KNOW HOW TO DISBATCH THOSE RESERVES. SH-RBGS SURE SO LET ME GO BACK TO GIVE THE HISTORY, SO THE EVEN IN THE CURRENT CONDITIONS, RIGHT? , OPERATE AT THE OWN LEVEL OF COORDINATORS PEAK AND THE NORTHWEST SHARING GROUP IS ACTUALLY ALREADY IN ALBERTA SO THERE'S ALREADY PROCEDURES AND AGREEMENTS TO THAT. SO WHAT WE DO IS WE BASICALLY TAKE THE SAME PROCEDURES AND AGREEMENT AND EXPAND IT, BUT SO WE WORK WITH SBP, BC HYDROS AND RC AND NORTHWEST POOLS FOR LOOKING AT ALL THOSE IN THERE. NORTHWEST POOL ACTUALLY HAVE INVOLVED WITH OUR RC TWO RC AGREEMENT AND COORDINATION AND SHARING GROUP, WE ACTUALLY HAVE ONE, AND I WILL LET ASHER TALK ABOUT IT BECAUSE IT'S MORE DIRECT INVOLVEMENT BUT THERE'S REALTIME WORKING GROUP THAT'S SPECIFICALLY TALKING ABOUT THE RESEARCH SHARING.

YEAH, I GUESS I SAT AT THE NORTHWEST POWER POOLS OFFERING COMMITTEE AND RESERVE SHARING GROUP COMMITTEE FOR A NUMBER OF YEARS AND ACTUALLY, I GUESS IN HINDSIGHT IT WAS PREDATES--MY INVOLVEMENT PREDATED PEAK, IT WOULD BE IN THE WEC, RC DAYS, SO AS MUCH AS, YEAH, WHAT WE'RE LOOKING AT IS, NORTHWEST POWER POOL, WILL ACTUALLY INCO AM PASS FOUR RC AREAS IN THE FUTURE AS DEDE SAYS THERE ARE PROCEDURES IN PLACE AND THE BAS WHAT'S BEEN KEYOT RESERVE SHARING GROUPS IS THE KIND OF TWO FRONTS, THE BAS ARE VERY ENGAGE INDEED THAT RESERVE SHARING GROUP AND ACTUALLY ACTIVELY BRING IN THE ACS TO SAY HEY, WE WANT TO MAKE SURE THIS CONTINUES TO WORK BECAUSE FOR THE BAS THE RESERVE SHARING GROUP IS FUNDAMENTAL TO THEIR OPERATION AND REALLY FOR THE RCS, LIKEWISE, IT DEFINITELY WILL BE, SO I DON'T HAVE REALLY MUCH MORE TO ADD THERE, IT'S JUST--IT'S A RECOGNITION, THIS IS WHAT WE'RE WORKING TOWARDS, AND THE BENEFIT THAT WE SEE MUST CONTINUE ON. SO INSURING THAT LEVEL OF ENGAGEMENT AND THE SUSTAINS IS REALLY CRUCIAL.

COMMISSIONER GLICK, I WOULD LIKE TO ADDED THAT RIGHT NOW IN THE SOUTHWEST POWER POOL IS THERE'S A GROUP PARTICIPANTS OUTSIDE OF THE DURING THE SEPARATE ABOUT BA AND RC AND WE HANDLE THAT VERY EFFICIENTLY IF TERMS OF THE BA SCHEDULING IF THEY LOSE A UNIT WE DISPATCH INTO THEM AND VICE VERSA SO WE LOOK AT THAT ON THE WESTERN SIDE BEING THE SAME SITUATION, WE'LL WORK WITH THE BA'S UNDERSTANDING WHERE THEY GET THEIR RESERVE SHARING WITH THE CONTINGE ENSEL SKPE BAKUGAN WHAT THE OBLIGATIONS ARE FOR IMPORTING AND EXPORTING IT IN A PARTICIPANT.

JUST IN THE EASTERN CONNECTION, WE HAVE VERY SAME PJM PARTICIPATES AND TWO RESERVE SHARING GROUPS THAT ARE OUTSIDE OF OUR RESERVE OBLIGATIONS SO WE FIGURE OUT TO YOU TO WORK THROUGH IT AND IT'S A SOLVABLE PROBLEM.

OKAY, GOOD SEGUE, MOVING ON TO THE EASTERN CONNECT AND WHAT LITTLE I DO KNOW ABOUT THESE ISSUES, I KNOW THAT JOINT APPLICATIONSERATING AGREEMENT TWEEZE MISO AND PJM WORKED WELL TOGETHER BETWEEN REGIONS AND HOW THEY PROVIDE SIGNIFICANT BENEFITS AND I UNDERSTAND FROM THE PART OF THE SHARING CONTRACT, DIVISIONS OF JOA IN PARTICULAR, AND MAYBE BE MORE IF YOU CAN TALK A BIT ABOUT HOW THAT MIGHT HAVE HELPED DURING SOME OF YOUR PEAK EVENTS, SPECS LEASH LEAK STREAM WEATHER LIKE JANUARY OF 2018 AND ALSO HOW THAT MIGHT HELP IF YOU HAD SIMILAR ARRANGEMENTS WITH OTHER REGIONS THAT SURROUND YOU.

SURE. YEAH. OUR AGREEMENT WITH PJM IS DIFFERENT THAN ANY OTHER SEAMS LIKE YOU MENTIONED, WE BASICALLY HAVE A COUPLE THINGS THAT ARE DIFFERENT. ONE IS WE DO HAVE A CAPACITY SHARING DIVISION OF JOINT OPERATING AGREEMENT THAT WE BOTH AGREE THAT ENABLING US TO USE EACH OTHER'S SYSTEMS. TALKED A BIT ABOUT THAT EARLIER, WE ALSO HAVE THAW AN OUTRATE WHICH HELPS BETWEEN MISO AND PJM, SO A COMBINATION OF THESE, YOU KNOW WE AS MICHAEL MENTIONED, WE FLOW POWER MORE DURING EMERGENCIES. WE FLOW POWER ACROSS EACH OTHER'S SYSTEM, DURING JANUARY YOU WERE IMPORTING QUITE A BIT TO US, 6500 MEGAWATTS, SO WE DO THAT ON IN AN EMERGENCY SITUATION. I THINK THAT COMMON UNDERSTANDING 85S US THE ABILITY TO HAVE FLEXIBILITY TO DEAL WITH AN EMERGENCY IN THE MOMENT AND NOT WORRY ABOUT THE FINANCIAL PIECES OF IT UNTIL AFTER THE FACT. AND I THINK THAT'S REALLY WHERE WE BENEFIT FROM THAT ON THAT THEME THAT WE CAN BENEFIT FROM IT ON OTHER SEAMS AS WELL. , WHAT ARE THE CHALLENGES OF REACHING THOSE AGREEMENTS WITHOUT REGIONS.

I THINK IT'S A PHILOSOPHICAL DIFFERENCE, WE'LL TALK ABOUT STM AND MISO HAVING A CONVERSATION ABOUT THAT. WE HAVE PHILOSOPHICAL DIFFERENCES AND I TALK ABOUT THAT IN MY ANALOGY AROUND THE USE OF THAT CAPACITY SHARING PROVISION, WE HAVE IT IN BOTH JUDGE, OAS, WE SEE IT DIFFERENTLY AND IT'S JUST ONE IS A COST AND OTHER IS USE OR PAY FOR USE OF THE SYSTEM. AND THOSE OF COURSE THROUGH THROUGH THE AGREEMENT WE HAVE TODAY, TKRASZ THE NORTH AND THE SOUTH AND IT MAKES IT MORE COMPLICATED AND A LITTLE MORE TRACKING ON ONE OF THE THINGS THAT HAPPENS NOW IS IF WE HAVE AN EMERGENCY SITUATION WHERE WE HAVE ONE OF OUR TRANSMISSION OWNERS THAT WILL FLOW ACROSS THE BORDER, ACCIDENTALLY ON TO A PEAK SYSTEM WHERE THEY HAVE A TRANSITION LINE OUT THEY PAY FOR THAT UNRESERVED USE FOR EXAMPLE IF THEY GO ON TO THAT SYSTEM WHERE THE OPPOSITE ISN'T TRUE ON MISO BECAUSE WE HAVE A DIFFERENT INTERPRETATION OF THAT CAPACITY SHARING SO THOSE ARE DIFFERENCES THAT WE MANIFEST THEMSELVES AND MAKE IT LESS SUFFICIENT.

SO ALONG THE SAME LINES YOU POINTED OUT IN YOUR TESTIMONY, THAT WAS EXCELLENT, DISCUSSION ABOUT TRANSMISSION LINE RATING AND I THINK YOU POINT OUT WHEN THERE'S A DISAGREEMENT BETWEEN MISO AND A NEIGHBORING REGION AND MOST CONSERVATIVE LINE RATING SO HOW DOES THAT IMPACT THE COLD WEATHER EVENT IN JANUARY OF 2018.

RIGHT. SO I WOULD SAY JUST BACKING UP TO JUST THIS LACK OF UNDERSTANDING AND WE TALK ABOUT IT TALKING THE SAME LANGUAGE WAS A REAL BIG--A BIG ISSUE KIND OF IN GENERAL BACK IN JANUARY OF 2018, IT WAS--WE TALK ABOUT COMMUNICATION BUT IT WAS UNDERSTANDING WHAT EACH OTHER'S TALKING ABOUT AND GOING AND ON YOUR TRANSMISSION LINE RATINGS WE WOULD GO TO THE MOST CONSERVATIVE RATING DEPENDING ON WHAT THAT RATING WAS ON THE TRANSMISSION SYSTEM WAS HAVING THE ISSUE AND I THINK IT'S JUST AN UNDERSTANDING. IT'S NOT HAVING THE SAME RATINGS NECESSARILY ACROSS BOTH OF THOSE POINTS OR EVEN WITHIN YOUR OWN BUT I THINK WHAT WE LEARNED WAS IT WAS IMPORTANT TO UNDERSTAND WHERE WE WERE SO THAT WE WERE MAKING THE RIGHT DECISIONS ON THE MOMENT IN RAOEUBLT BOTH FROM EMERGENCY PROCEDURES AND HOW WE CALL EMERGES AND WHAT WE TALK ABOUTURE DIDDING EMERGENCY AND WHAT THOSE LINE RATINGS WERE, SO THEY DID MAY AN IMPORTANT ROLE, BUT I THINK BIGGER PICTURE, IT'S THE LACK OF AWARENESS OR COMMON LANGUAGE WITHIN THE TIME FRAME THAT DRIVES YOU TO THE LEAST COMMON DENOMINATOR WHEN YOU HAVE THIS CONVERSATION.

DO HAVE YOU THIS EXPERIENCE WITH YOUR NEIGHBORRINGS?

IT'S INTERESTING BECAUSE I REMEMBER THE EARLY DAYS OF JOAS AND THE WE'VE DONE THIS WITH NEW YORK AS WELL IS ONE OF THE WAYS WE SOLVE THOSE LANGUAGE PROBLEM ANDS AND WE SENT OPERATORS THAT ARE WOULD SIT IN THE OTHER CONTROL ROOM DURING THESE OPERATIONS AND PARTICULARLY DURING CUT OVER OPERATIONS, AND THEY WILL COME BACK TO US AND SAY THAT'S NOT WHAT THEY'RE TALKING ABOUT. YOU KNOW AND SO THAT HELPED US WORK THOSE THINGS OUT SO I WOULD ENCOURAGE EVERY OPPORTUNITY TO DO THAT IN THE SEAMS AND WE EXCHANGE THE PEOPLE WHO ARE ON THE FLOOR AND MAKING THE DECISIONS AS MUCH AS POSSIBLE AND I KNOW YOU'VE DONE THAT TO SOME EXTENT AS WELL, PARTICULARLY IN THE PARALLEL OPERATIONS BUT CERTAINLY, I KNOW AND WHEN I THINK ABOUT OUR SEAM WITH NEW YORK, IS NEW YORK FOR BEING A SINGLE STATE AS HORMONE ON ON THEM, THEY HAVE POWER OF AUTHORITY, THEY HAVE NCC THAT HAS A REGIONAL SET OF STAND ARMEDS SO WHEN WE CREATE A FLOW GATE AND FIGURE THAT OUT, WE HAD TO COME UP WITH ONE OF THE--YOU KNOW IT WAS NOT A GOOD APPLES TO APPLES WE HAVE TO COME UP WITH A WAY TO DEFINE THE FLOW GATE, LET'S FIGURE OUT A WAY THAT WE'RE BOTH TALKING ABOUT THE SAME THING BUT WE WORK THROUGH IT WITH OUR JOA WITH NEW YORK.

SO DO I WANT TO COMMENT ON THAT AT ALL?

I WAS JUST GOING TO MENTION ONE MORE THING. WHAT'S REALLY IMPORTANT THAT WE TALK ABOUT IS SOMETIMES IN A MOMENT YOU'RE CREATING THESE DURING OPERATING AGREEMENTS AND YOU BEING YOU HAVE THE BEST INTENTIONS EVEN THE OPERATING PROCEDURES WE HAVE UNDER OUR AGREEMENT AND THEY'RE VERY--THEY'RE VERY GOOD IN THE MOMENT BUT WHEN YOU GO INTO AN EMERGENCY SITUATION IT HIGHLIGHTS THE IMPORTANCE OF THAT ENHANCED COMMUNICATION OR THAT COORDINATION AND IT REALLY IS SPEAKING THE SAME LANGUAGE BECAUSE IF YOU'RE ON A SYSTEM AND YOU ARE CALLING AN EVENT, IT MEANS SOMETHING DIFFERENT TO ME THAN IT DOES TO STP BECAUSE IT'S NOT APPLES TO APPLES SO WE HAVE GONE THROUGH AFTER SEPTEMBER OR JANUARY 17TH IN 2018 WE SPENT A YEAR WORKING THROUGH THAT WITH STP TBA AND SOUTHEASTERN RC AND I THINK WE COME TO A GOOD PLACE, BUT YOU KNOW WHEN WE TALKING ABOUT THE LEFT, I THINK YOU HAVE TO THINK ABOUT, YOU'RE NOT GOING TO GET EVERYTHING, RIGHT THE FIRST TIME, SO IT'S GOING TO BE IMPORTANT TO KEEP, YOU KNOW KEEP THIS CONVERSATIONINGS GOING AFTER THE FACT AND DO A LOT OF LESSONS LEARNED.

SO COMMISSIONER LAFLEUR MENTIONED EARLIER IN THE DAY ABOUT THE MORE EXTREME WEATHER CONDITIONS WITH POLEAR VORTEXES AND OTHER COLD WEATHER EFFECTS ANDHEAT WAVES AND IT'S SOMETHING WE NEED TO WORK ON AND CONSIDER IS MAKING SURE THE REGIONS WORK TOGETHER AND HAVE THE RIGHT COMMONALITIES SO IT IS AN INTERESTING ISSUE. SO.

BEFORE GOING TO QUESTIONS FROM THE STAFF, ONE THING I NOTICED IN THIS CONVERSATION WHICH WAS HEARTENING IS THAT THERE'S UNIVERSAL AGREEMENT THAT DON'T RELYOT LAWYERS TO HANDLE A CRISIS SO I WHOLLY THANK YOU ALL FOR NOT RELYING ON THOSE. [LAUGHTER]

ANY QUESTIONINGS? , I WILL THROW ONE OUT THERE, THIS ACROSSS SEAM ISSUE WITH PANEL TWO AND THREE, WITH ALL THE DATA SHARING HOW DOES CLOUD COMPUTING LEND ITSELF TO INEFFICIENCIES?

IT'S INTERESTING, BRUCE AND I WERE BOTH ON A SEARCH ADVISORY PANEL TO DOE AND THIS CONVERSATION CAME UP AND I THINK THERE WAS A GUY THERE WHO WORKED WITH THE NATIONAL SECURITY AGENCY THAT TOLD US WE'RE USING IT, GET OVERIT WHICH I THOUGHT WAS INTERESTING BECAUSE YOU KNOW WE ARE USING CLOUD COMPUTING FOR BACK OFFICE TYPE STUFF. WE'RE NOT--WE'RE NOT QUITE THERE, BUT ONE OF THE THINGS THAT--IN FACT NEW YORK ISO TALKED ABOUT IT ON THE PANEL IS THEY WERE USING IT FOR PLANNING ABNORMALITIES LIGATIONS BECAUSE IT GIVES THEM ABILITY TO SHARE DATA TO SHARE APPLICATIONS AND DO CALCULATIONS FASTER. AND IT MAY BE PARTICULARLY FOR SCENES TYPE THINGS THAT MAY BE AN OPPORTUNITY. I KNOW WE'RE NOT THERE YET, BUT--

MOST OF MY QUESTIONS HAVE BEEN ANSWERED BUT I HAVE A COUPLE QUESTIONS AND THE FIRST QUESTION IS FOR DEDE BRUCE. MAYBE YOU COULD TALK A BIT ABOUT YOUR INVOLVEMENT IN EACH OTHER'S RC CERTIFICATION PROCESS?

SO ON THE FIRST--WE'VE BEEN CALLING IT THE FITTER BASE HAD WHICH IS THE JULY 1 PHASE, WE HAVE PEOPLE FROM STP CAME OVER AND PARTICIPATE IN OUR CERTIFICATION PROCESS AND WE ARE ACTUALLY NOT QUITE OF THE RC WEST BUT THE CALIFORNIA ISOS DIRECTORS AND OTHERS WILL BE PART OF THE CERTIFICATION SUPPORT PORTIONS IN THERE.

YEAH, LIKE DEDE SAID WE HAD TWO STAFF THAT WENT OUT THERE FOR THE SURIDATION OF THEIR CERTIFICATION, OUR CERTIFICATION IS--BEGINS AUGUST 14TH AND THEY WILL BE PARTICIPATING IN THAT.

OKAY, GREAT. SO THEN, I HAVE ONE FOLLOW UP QUESTION, I UNDERSTAND THAT PEAK, HAD THIS MASTER MODEL, OF ALL THE REMEDIATE ACTION SCHEMES OF THE INTERACTION CONNECTION AND I UNDERSTAND THE LARGE NUMBER OF THOSE SCHEMES ACTUALLY SPAN MULTIPLE RC FOOTPRINTS. SO WHAT EFFORTS ARE YOU TAKING TO INSURE THAT THE REMEDIAL ACTION TEAMS ARE ACTUALLY PLANNED FOR AND OPERATED CORRECTLY IN REALTIME IN AND YOU'RE TAKING INTO ACCOUNT YOUR OPERATING GLOBALLY RAYINGS WHEN YOU THE REMEDIAL ACTION SCHEMES SPAN MULTIPLE RCS?

SURE. AS PART OF THE PLANNING TO IMPLEMENT THAT, THE NEW IRO, TO STANDARDS, REGIONAL VARIANCE, WE HAVE A FULL FULL STAFF THAT THE COMMISSIONERS CAN APPROVE IT ANYTIME SOON HERE, BUT AS PART OF THAT WE'RE ACTUALLY--WE'VE MOVED AHEAD TO ACTUALLY WORK ON THE COMMON MODEL, AND COMMON METHODOLOGY. THE COMMON MODEL WORK DONE AND THE COMMON METHODOLOGY WORK DONE IS ACTUALLY PERSONALLY LEADING THAT EFFORT FOR THE WESTERN CONNECTION AND PART OF THAT IS ACTUALLY THE EXCHANGE OF THE REMEDIAL ACTION DATA FOR THIS AUTOMATION STUFF AND DATA AND HOW TO MODEL IT, HOW TO MODEL IS AND HOW TO EXCHANGE THOSE DATA SO WE HAVE ENGINEERS FROM MY SHOP, BRUCE SHOP, EVERYBODY'S ACER SHOP AND AND WE BASICALLY GET AN AGREEMENT ON HOW WE WANT TO EXCHANGE IT AND HOW WE MAKE SURE WE CONTINUE TO DO THAT. AND WEC, HOLDING US ACCOUNTABLE AND EVERY TIME WE HAVE THAT CERTIFICATION PROCESS THEY ASK THAT QUESTION. SHOW ME, I WANT TO SEE IT, HOW DOES THAT WORK. AND FOR US, AND THE RC WEST OR CALIFORNIA ISOS BECAUSE WE HAVE BEEN PART OF THIS WESTERN CONNECTION, OUR REALTIME OR REALTIME ANALYSIS IS MADE UP FOR THAT, SET UP FOR THAT, OUT OF THE 200 AND SOMETHING ACTION SCHEME WE HAVE BEEN AND WHAT WE DO WITH THAT, AND THAT MODULE AND DO THAT, WE'RE ALSO WORKING THROUGH IT AND WORKING THROUGH IT, AND AS WOO WE'RE ACTUALLY MOVING FORWARD FOR THE RELIABILITY EXPANDING AND AND GO BACK IN 2021, I BELIEVE, SO IT'S THE NEW STANDARD THEY BELIEVE THAT'S APPROVED, IN THE WESTERN CONNECTION IT'S IMPORTANT, SO WE'RE ACTUALLY PLANNING TO DO THAT AHEAD OF TIME IN THE 2020 TIME FRAME AND I'M ALSO CHAIRING THAT UNDER THE UMBRELLA OF WEC SSO THERE'S GOOD COORDINATION OF NDRC TO FOR THE RAS DATABASE MODELING AND WHAT NOT.

BRUCE, ANYTHING TO ADD?

NO I THINK DEDE COVERED MOST OF IT AND HE'S LEADING THAT EFFORT IN THE WEST AND WE'RE WORKING 32 YOU UNDERSTANDING AND APPRECIATING EACH OF THOSE SCHEMES THAT ARE THERE.

OKAY, THANK YOU.

ANYONE ELSE.

WE HEARD A LOT ABOUT THE SLIDE, TOOLS AND METRICS AND I WAS CURIOUS IF THE EAST WAS ALL THE DIFFERENT RCS OVER THE YEARS DEVELOP THE THOSE TOOLS OR METRICS OR THE AREAS WELL ALL THE RCS COULD LEARN AND DEVELOP COMMON TOOLS AND METRICS THAT MIGHT BE USEFUL.

SO I KNOW WITH AND I CAN'T SPEAK FOR ALL THESE WE USE ONE CREATED AS *EURBT FACES BETWEEN THE TOOLS THEY ALLOW PEOPLE TO TALK TO US, SO WE MIGHT HAVE FOR INSTANCE A MODULE OF OUR SECURITIES CONSTRAINED ECONOMIC DISBATCH IS THE END TO EPD PIECE SO THERE'S A--IT'S NOT A WHOLE TOOL THAT WE ALL USE TOGETHER BUT WE'VE CREATED INTERFACE TOOLS THAT REALLY TALK BETWEEN THEM.

MAYBE I'LL ADD TO THAT A LITTLE BIT. THIS WHOLE PROCESS AS BEEN VERY INTERESTING TO ME BECAUSE I CAME FROM THE INTERNET CONNECTIONS AND GET TO KNOW EVERYBODY AND 15 YEARS AGO, AGAIN, ONE OF THE BIGGEST TOOLS THAT'S COMMONLY USE SIDE FOR TRANSMISSION LOADING AREY LEASE, THE NERC IDC, DLR FOR WHAT'S IN THERE, ANDEE HAVE THE COMMON TOOL THAT WE CALL ENHANCED CALCULATOR WHICH IS REALLY JUST THE SAME THING THAT THE PLR AND THE FEE IS ACTUALLY EVEN THE SAME STANDARD, SO WHAT WE'VE ACTUALLY BEEN WORKING OUT IS ACTUALLY TRY TO COMPARISON WITHIN THE WESTERN AND TRY TO FIGURE OUT WHAT IS THE BEST PRACTICE SO WE'VE BEEN IN CONTACT WITH PEOPLE THAT BEGAN MISO AND TO ACTUALLY HAVE THIS COMMON DISCUSSIONS ABOUT WHAT COULD WE LEARN FROM EACH OTHER, SO THIS IS ACTUALLY AN EXCITING TIME AT LEAST FOR ME, TO BE ABLE TO DO THAT COMPARISON AGAIN. , THERE IS A NERC SET OF TOOLS THAT'S OVER, SO THOSE I WOULD SAY ARE COMMON, BUT I THINK THAT THOSE ARE ALMOST TERTIARY TOOLS FROM AN OPERATOR PERSPECTIVE. THOSE TOOLS ARE DATA SHARING IN TERMS OF FLOWS AND WHAT'S GOING ON IN THE SYSTEM AND RATHER THAN DOING CALCULATIONS.

OKAY, I TRY TO MAKE THE POINT THAT I'M NOT SURE WHAT THEY DO AND ONE THING THAT'S UNIQUE AND PERFORMNESS AND IT'S REALLY ABOUT THE QUALITY OF DATA PROVIDED BY THE VIEW AND REALLY, ONE OF THE DISTINCTIONS WE CAN MAKE WITH THE CONNECTIONS DUE TO THE DYNAMIC NATURE OF THE OPERATING LIMITS, WE'RE ONLY AS STRONG AS OUR WEAKEST LINK SO THAT'S ONE CRITICAL DISTINCTION IS THAT DATA QUALITY.

MAYBE IF I CAN ADD TO THAT, LET'S GO THROUGH THE DISCUSSION, I REALLY LIKE THAT BECAUSE YOU, YOU KNOW WE COULD GET BETTER AS LONG AS WE KNOW WHERE WE ARE RIGHT NOW AND WE WANT TO STRIVE TO BE BETTER. IN PEAK'S COMMISSIONER'S KD--SALLY--[INDISCERNIBLE] IT SENDS BACK THOSE BA AND GIVING THE DAILY BASIS THEA OF THE QUALITY THAT THE BA'S GIVING AND THEN THERE'S ALSO METRICS LIKE BRUCE IS TALKING ABOUT ON HOW PEAK DO THEIR OPERATIONS ITSELF. IT'S LIKE A THRESHOLD DIFFERENT METRIC THAT ARE THERE AND AS I TALK WITH PEAK AND--AND ALSO THIS MORE CONFIDENTIAL AND HOW GOOD YOUR BA IS DOING IS THE METRICS FOR US IN WHAT THE SYSTEM WAS.

I WANTED TO ASK ONE MORE QUESTION WHICH PICKS UP ON SOME OF WHAT I WAS TALKING ABOUT BEFORE. WHEN I WAS COMPARING AND CONTRAFRTING THE WEST WITH THE AREAS AND BOOK AT THE BALANCING AND THE MARKET IT THE ADVANCE MARKET AND SBP TALKED ABOUT SELLING MARKET SERVICES IT TO THE WEST. I GUESS STARTING WITH DEDE COULD YOU COMMENT ON HOW THOSE COMPLEMENT EACH OTHER SO I ASSUME IF YOU'RE DOING CAPACITY SHARING AND ENERGY AND WILL BAANCE MARKET, THAT I WOULD THINK COMPLEMENTS YOUR RC FUNCTION OVER THE SAME FOOTPRINT AND IT SEEMS LIKE THERE'S A POTENTIAL AS MARKETS GROW MORE IN THE WEST TO GET SOME OF THOSE SAME SYNERGYS.

SURE. YEAH. THERE ARE ACTUALLY TWO THINGS THAT ARE VERY GOOD THAT END UP HAVING THAT MARKET AND THE DRCS TOGETHER. NUMBER ONE IT'S THE ABILITY TO DO A LOOK AHEAD. AND THIS IS ACTUALLY SOMETHING THAT WE STRIVE TO BE PROVIDING A BETTER ENHANCED SERVICE FOR OUR RC FOOTPRINT IS THE ABILITY TO LOOK AHEAD. RIGHT NOW, WITH--IF YOU'RE JUST DOING THE RCS, ALL THE DATA YOU'RE GETTING IS THE FORECAST DATA ASK REALTIME DATA WHERE IF YOU ARE DOING THE MARKET AND THE RCS NOW WHEN I DO THE MARKETS I'M DOING AND COMMITTING UNIT AHEAD OF TIME, IN THE DAY I HAVE, THE OUR I HAVE, SO WITH THAT LOOK I HAVE, AS OF MONDAY, WE PUT A LOOK AHEAD ABILITY, IT'S NOT JUST REALTIME ASSESSMENT NOW WEB CONNECTED HAVE A LOOK AHEAD ASSESSMENT THAT THEY LOOK AT OUR HAT, THE NEXT MINUTES AND ALL THAT. SO THAT'S ONE OF THE MOST EFFICIENT THINGS THAT'S GREAT ABOUT HAVING THAT TO BE COMBINED. THE OTHER THING IS GOING BACK ABOUT METHODOLOGY, COMMON LANGUAGE, IN THE INTERNET CONNECTIONS WE CALL THIS CONGESTION MANAGEMENT. IN THE WEST OTHER THAN CONNECTIONS WE CALL IT AN SOL EXCEEDED MITIGATION, THERMAL OVERLOAD, THEY'RE ALL THE SAME BUT IT'S DIFFERENT LANGUAGE. SO BEING ABLE TO MITIGATE POTENTIAL SOL AND LIMIT EXCEEDENTS IN THE WESTERN AREA, INSTEAD OF JON JESTION MANAGEMENT, IT'S MORE EFFICIENT WHEN YOU ARE DOING IT THROUGH THE MARKET BECAUSE IT'S A SOLUTION THAT'S IN THERE, THAT'S WHERE THE TOOL IS. SO RIGHT NOW, CALIFORNIA ISO AND THE NEIM MARKET HAS THE DISPATCH THAT ALLOWS US TO RELIEVE THE THERMAL OVERLOAD EAR LIMIT THE EXSEATENTS IN THE DIFFERENT MANNER. THOSE WHO ARE IN THE MARKET WOULD DO MORE OF A MAP UP, AND THAT'S WHY WE HAVE THE ENHANCED OF THAT BUSINESS.

SO YOU'RE GOING TO RUN AN RC WHERE MANY OF THE PEOPLE AND SEEMINGLY MORE OVERTIME WITH THE AND MARKET SERVICES OR NOT, SO THAT'S ANOTHER,.

RIGHT. JUST LIKE ALL THE COMBINATIONS, ITS IT'S A BA, WE HAVE A POP, WE'RE A MARKET OPERATORS, CALIFORNIA ISOZ HAVE AN RC BUT THE RC FOOTPRINT IS NOT NECESSARILY THE SAME. SO THAT'S TRUE.

COMMISSIONER LAFLEUR, ONE THINK THIS WE WOULD LIKE TO ADD IS THEY BRING A TIGHTER OPERATION TO THE MULTIPLE VAS, THEY DO A FIVE MINUTE DISBATCH IN THAT TIME, COORDINATING AND LOOKING AT THAT, DOING SECURITY CONSTRAINT ECONOMIC DISBATCH ON A WIDER AREA SO IT BRINGS OPERATION TIGHTER TOGETHER AND YOU KNOW WE TALK ABOUT EARLIER, THAT'S A TOOL THAT YOU USE BEFORE THE RELIABILITY SO IT ENHANCES OPERATION BY ADDING MARKETS AND MAKING IT MORE EFFICIENT.

BUT SIT NOTHING LITTLE ROCK YOU'RE GOING TO DO THAT IN TWO DIFFERENT THINGS RIGHT? I KNOW THERE'S A COUPLE DC TIES BUT YOU'RE GOING TO BE RUNNING THIS MARKET IN RC AND THEN A SEPARATE I WANT TO SAY COMPUTER BUT A SEPARATE PLATFORM FOR THE WEST BECAUSE IT'S NOT LIKE ONE BIG--RIGHT?

SURE. WE WILL HAVE THE STAFF WHEREVER THEY'RE SITTING THEY'RE DEDICATED TO LOOKING AT RELIABILITY SERVICES IN THE WEST OR MARKET SERVICES IN THE WEST SO THAT WILL BE THEIR FOCUS AREA, AND THEY WILL BE LOOKING AT THE REALTIME CALCULATIONS AND MAKING DECISIONS BASED ON THAT.

THANK YOU. ANYONE ELSE?

THANK YOU IF ARE THAT QUESTION, CHAIR OF THE WESTERN E IM BODY REGULATORS MY FEELINGS WERE HURT THAT WE WOULD NOT TALK ABOUT TERMS OF RELIABILITY SO I WANT TO THANK YOU. WE TALK ABOUT OUR COST BENEFITS AND POTENTIAL MARKET SOLUTIONS BUT THAT'S REALLY SOMETHING THAT'S NOT DISCUSSIBLE WHICH IS A RELIABILITY BENEFIT AND I WANT TO COMMEND FERC STAFF, THEY DID A WHITE PAPER 2012 OR 13 THAT DID A DETAILED DISCUSSION OF WHAT THE RELIABILITY BENEFITS ARE PROVIDED BY THEM AND I WANT TO ADD ON TO THAT AND THANK YOU FOR THE QUESTION.

I KNOW TRAVIS WILL APIECE THE FERC IN THEIR FAIR WELL LETTERS TALK ABOUT THE IMBALANCE MARKET, SO I DON'T PLAN TO TAKE ANY CREDIT FOR IT WHATSOEVER BUT I DO THINK IT'S ONE OF THE EVOLUTION IN THE WEST IS ONE OF THE MOST EXCITING THINGS FOR THE LAST DECADE. WITHOUT DOUBT SO THANK YOU FOR YOUR EFFORTS FROM YOU AND YOUR COLLEAGUES.

ALL RIGHT IF THERE ARE NO MORE QUESTIONS, WE REALLY APPRECIATE YOU BEING HERE. THESE ISSUES ARE VITALLY IMPORTANT. WHAT'S HAPPENING IN THE WEST, COMMISSIONER LAFLEUR, IT'S EXCITING TO SEE WHAT'S HAPPENING BUT CAN'T FORGET THAT THE FACT THAT WE DON'T SEE THE ISSUES THAT YOU ALL ARE MANAGING THINGS REALLY WELL, THE REST OF THE COUNTRY, NORTH AMERICA, IS A CREDIT AND SOMETHING THAT WE'RE WATCHING, BE VIGILANT ABOUT BUT IT'S IMPORTANT, I'M BLAD WE DO THESE THINGS AT THE TECH IN IICAL CONFERENCES AND THAT HELPS MAKE EVERYBODY AWARE OF WHAT'S GOING ON BEHIND THE SCENES IN A SENSE. SO THANK YOU VERY MUCH. WE'RE WE FINISHED A BIT EARLY. WE WILL RECONVENE AT 3:30 TO BE CONSISTENT WITH THE NOTICE WE PROVIDED FOR TIMING SO GIVE MORE TIME FOR PEOPLE TO CHECK E-MAILS AND EVERYTHING ELSE SO WE WILL RECONVENE AT 3:30 [PROGRAM IS ON A SHORT BREAK ]

RATHER, BEFORE I WELCOME OUR FINAL PANEL OF THE DAY, I WANT TO THANK COMMISSIONER MC NAMEE FOR HOLDING DOWN THE FORT. MUCH APPRECIATED. ALSO WANT TO NOTE VERY BRIEFLY WE'VE GOT A SLIGHT CHANGE IN THE THIS FINAL PANEL. OUR PANELISTS FROM SOUTHERN COMPANY WAS UNABLE TO JOIN US TODAY BUT I DO WANT TO THANK HER FOR HER THOUGHTFUL TESTIMONY AND MUCH APPRECIATED. FINALLY I WANT TO WELCOME A SPECIAL GUEST CHRIS ANDERSON, THE CHIEF OPERATIONS AND EMERGENCY MANAGEMENT OFFICIAL AT THE SEC, HE IS AN INCIDENT MANAGEMENT AND PROTECTION EXPERT WITH ALMOST THREE DECADES OF GOVERNMENT, MILITARY AND PRIVATE SECTOR EXPERIENCE. HE IS CURRENTLY THE SEC'S CHIEF OF OPERATIONS AND EMERGENCY MANAGEMENT IN THAT ROLE HE IS RESPONSIBILITY FOR THE COMMISSION'S INCIDENT MANAGEMENT ACTIVITY AND KHR*EUPB UDPGAING THE MANAGEMENT OF TWO OPERATION CENTERS, THE SEC'S SECURITY COORDINATION AND CONTINUITY OF OPERATION AND GOVERNMENT PROGRAMS. SO WELCOME CHRIS AND THANK YOU FOR BEING HERE. AND WITH THAT I WILL TURN IT OVER TO OUR PANELISTS. THANK YOU.

THANK YOU. COMMISSIONERS THANK YOU FOR THE OPPORTUNITY TO JOIN THIS PANEL TODAY. MY FULL OPENING COMMENT VS BEEN FILED AND AVAILABLE TO REVIEW, IN THE INTEREST OF TIME I WOULD LIKE TO EXPLAIN WHY I AM HERE AND WHAT THE INDUSTRY AND CUSTOMERS THEY SERVE NEED FROM YOU. PRIOR TO JOINING NTEARE, ICS FORMERLY PDB WIRELESS, I SPENT 30 YEARS IN THE INDUSTRY, MOST OF THAT TIME I WAS RESPONSIBLE FOR COMMUNICATIONS AND INFRASTRUCTURE, I LIVED THROUGH THE CHALLENGES IN THAT UTILITY SPACE DURING THAT TIME. I PASSED SEVERAL NERC RELIABILITY AUDITS WHERE I WAS ALSO REPASSED FOR THE AUGHT EDUCATIONAL, UTILITIES TRIM TREES AND THEY HAVE RESIL VENT COMMUNICATIONS CAPABILITIES BETWEEN THE RELIABILITY COORDINATOR, TRANSMISSION OPERATORS AND BALANCING AUTHORITIES. THE AUDIT CANNOT CONTINUE UNLESS THESE REQUIREMENTS ARE MET. CLEARLY YOU RECOGNIZE THE IMPORTANCE OF RELIABLE COMMUNICATION FOR ELECTRIC SERVICE RELIABILITY WHICH IS OF COURSE THE TOPIC OF THAT CONFERENCE. PRIVATE COMMUNICATION NETWORKS CONTINUE TO BE THE BEST SOLUTION TO SUPPORT THE SAFE AND RELIABLE DELIVERY OF ELECTRICITY. WHILE THE PAST WAS DOMINATED BYIFIABLER AND MICROWAVE, THE FUTURE IS BROAD BAND NETWORKS ON ON THE GLOBAL NTE STANDARD, I ARE JOINED TO DELIVER ON THAT MISSION. TODAY WE HAVE A ONCE IN A GENERATION OPPORTUNITY FOR CRITICAL INFRASTRUCTURE PROVIDERS TO DEPLOY WIRELESS NETWORKS THAT MEET THEIR RAOEUBLT, RESILIENCYS, PERFORMANCE AND MOST IMPORTANTLY CYBERSECURITY REQUIREMENTS. AND NETWORK UTIL DECIDES WHERE COVERAGE EXISTS, WHEN UPGRADES ARE PERFORMED, WHAT DEVICES CAN CONNECT AND THAT IT CAN BE ISOLATED FROM THE INTERNET. PUT SIMPLY UTILITIES NEED CONTROL OF THESE CRITICAL COMMUNICATIONS NETWORK. MY FELLOW UTILITY PROFESSIONALS AGREE, IN A RECENT FCC FILING, SOUTHERN CALIFORNIA EDISON ONE OF OUR LARGEST UTILES STATED ISSUES ELECTRICT UTILITY INDUSTRY IN THIS COUNTRY IS NOW AT AN HISTORIC THRESHOLD. THE TELECOMMUNICATIONS METHOD, NETWORK AND EQUIPMENT OF THE 20TH CENTURY ARE NO LONGER UP TO THE TASK OF MEETING 21ST CENTURY CLIMATE CONTKEUPGZS AND SECURITY THREATS AND NOT THE MENTION THE INCREASING COMMR. EXPECTATIONST OF ADMINISTERING THE INTERCONNECTED GRID THAT MAKE UP THE NATION'S ELECTRICAL INFRASTRUCTURE. SEC VIEWS THE CURRENT PROCEEDING AS HOLDING NOTHING LESS THAN A POTENTIAL DEFINING ONCE IN A GENERATION IMPACT ON THE ABILITY OF UTIL IS TO CONTINUE TO DELIVER SAFE AND RELIABLE POWER TO THEIR CUSTOMERS FOR DECADES TO COME. WHAT THE UTILITY INDUSTRY AND THE CUSTOMERS THEY SERVE NEED IS FERC'S LEADERSHIP TO PRESS THE FEDERAL COMMUNICATIONS COMMISSION TO MOVE URGENTLY TO MAKE LICENSED SPECTRUM INCLUDES 900 MEGAHERTZ BROAD BAND SPECTRUM TO MEET CRITICAL COMMUNICATIONS DATA NEED -FRPLT THANK YOU. NEXT GOOD AEFRP I'M J. P. BUM AN, VICE PRESIDENT OF BUSINESS PLANNING AT ALLIANCE ENERGY, MIDWEST UTILITY OF ABOUT 400,000 GAS CUSTOMERS LOCATED IN IOWA AND WISCONSIN. I WANT TO THANK YOU FOR THE OPPORTUNITY TO BE HERE TODAY ON BEHALF OF THE EDISON ELECTRIC INSTITUTE AND FOR PROVIDING THIS FORUM TO DISCUSS THE CHALLENGES OUR INDUSTRY SEES WITH THE FEDERAL COMMUNICATION COMMISSION PROPOSED POLICY CHANGES REGARDING ACCESS TO THE SIX GIGA HERTZ BAND AND THE POTENTIAL I AM NOT PACT EXCHANGES WOULD HAVE ON THE RELIABILITY OF THE ELECTRIC GRID. MY REMARKS TODAY WILL FOCUS ON THE CHALLENGES THAT OUR INDUSTRY FACES DUE TO THE GROWING INDEPENDENCE OF THE ELECTRIC AS WELL AS COMMUNICATIONS INFRASTRUCTURE. EEI AND ITS MEMBERS HAVE LONG SUPPORTED BROAD BAND DEPLOYMENT THROUGHOUT THE UNITED STATES. THE DEPLOYMENT OF BROAD BAND SHOULD BE BALANCED HOWEVER WITH THE NEED TO MAINTAIN SAFE RELIABLE AND COST EFFECTIVE ELECTRIC INFRASTRUCTURE WHICH DEPENDS ON PROTECTING OUR PRIVATE WIRELESS NETWORKS FROM HARMFUL INTERFERENCE. WHEN I START--FIRST STARTED WORKING AT ALLIANCE ENERGY, I HAD THE PRIVILEGE TO WORK IN A CONTROL CENTER WHERE WE CONTROLLED OUR SYSTEM FREQUENCY. THIS WAS BEFORE MISO, BUT AS I'M SURE YOU KNOW, ELECTRICITY IS GENERATED EXACTLY WHEN WE NEED IT AND I WAS FASCINATED TO SEE HOW OUR--AS THE FREQUENCY WOULD CHANGE A LARGE GENERATOR WILL WOULD TRIP OFF, THESE CONTROL SYSTEMS IN SECONDS WOULD SEND OUT SIGNALS TO OUR GENERATES ACROSS IOWA AND WISCONSIN AND THEY COULD RESOUND THOSE FREQUENCY CHANGES. THAT'S CHANGED A BIT WITH MISO, IT'S CONTROLLING THE FREQUENCY BUT WE STILL HAVE THESE CONTROL SYSTEMS, THEY'RE SENDING THE SUBPOINTS TO OUR GENERATORS AND THEY'RE PROVIDING MERMISSION BACK TO MISO AND I BREAKTHIS UP BECAUSE IT'S THESE COMMUNICATIONS ARE THE ONES THAT WE ARE TALKING ABOUT. THESE ARE THE COMMUNICATIONS THAT ARE USING THESE PRIVATE WIRELESS NETWORKS OVER THE LICENSED SIX BIGGA HERTZ NETWORK. BUILDING ON THAT A BIT MORE, WHEN I WAS--IN CONTROL ROOM, IT'S A LOCKED ROOM. SO NOT ONLY DO I YOU NEED TO GET INTO THE BUILDING BUT YOU 92 ED TO GET INTO THE ROOM. IT'S VERY SECURE. THE SOFTWARE SYSTEMS ARE IN A SERVER ROOM THAT IS LOCKED AWAY FROM THE LARGER SERVER ROOM OF OUR COMPANY. SO IT IS ALSO VERY SECURE. IT'S SENDING MESSAGES OUT INTO THE FIELD AS I NOTED, THEY HAD SIMILARLY LOCKED DOWN FACILITIES THAT ARE GETTING THESE SYSTEMS. SO I BRING THIS UP JUST TO MENTION THAT THESE ARE VERY CRITICAL PROCEDURES AND THE THINGS THAT WE OPERATE, THESE ARE THE ONES THAT HAVE TO COMPLOY TO A LOT OF DIFFERENT NERC RELIABILITY STANDARDS AND THESE ARE THE STANDARDS THAT IF THEY'RE VIOLATED THEY COME WITH SANCTIONS THAT COME AS HIGH AS A MILLION DOLLARS PER PER DAY PER INCIDENCE. --ON THE SAFETY AND SECURITY OF OUR SYSTEM AND I LOOK FORWARD TO DISCUSSION AND DID QUESTIONS THAT YOU ASK.

THANK YOU SO MUCH FOR THE OPPORTUNITY TO BE HERE TODAY. I AM JOEY DITTO AND I'M PRESIDENT OF UTILITIES TECHNOLOGY COUNCIL. UTV IS THE GLOBAL ASSOCIATION REPRESENTING ELECTRIC, WATER, GAS UTILITIES OF AUGHT TYPES ON INFORMATION AND COMMUNICATIONS TECHNOLOGY NEEDS. UTC WAS FORMED IN 1948 WHEN ELECTRIC UTILITIES BEGAN TO NEED HIGH LEVELS OF COMMUNICATIONS RELIABILITY TO UNDERPIN THE HIGH LEVELS OF--SUCH HIGH LEVELS OF COMMUNICATIONS RELIABILITY WERE EITHER NOT AVAILABLE OR NOT AFFORDABLE FROM THE TRADITIONAL TELECOMMUNE CARRIERS SO UTILITY BUILT THEIR OWN NETWORK. TODAY, UTILITIES PRIVATE COMMUNICATIONS NETWORKS ARE BUILT OF BOTH WIRE LINE AND WIRELESS INFRASTRUCTURE. ANY WIRELESS TECHNOLOGY IS DEPENDENT ON SPECTRUM TO OPERATE. SPECTRUM IS A NATURALLY OCCURRING PHENOMENON, THE ACCESS TO WHICH IS GOVERNED PRIMARILY BY THE FEDERAL COMMUNICATION COMMISSION. THE SPECIFICS OF UTILITIES COMMUNICATIONS NETWORKS VARY, GEOGRAPHY AND ACCESS CAN IMPACT THE ABILITY OF WIRE LINE NETWORKS WHILE TERRAIN CAN IMPACT WIRELESS COMMUNICATION, THE UTILITY EXPERIMENT IS LIMITED BY FCC POLICY, HENCE THESE FEATURES CREATE REDUNDANCY AND RELIABILITY. BECAUSE EVERY ELECTRIC UTILITY IS EXPECTED TO PROVIDE SAFE, RELIABLE AND AFFORDABLE ELECTRICITY, UTILITY COMMUNICATIONS NETWORKS HAVE BEEN BUILT WITH THIS TOP OF MIND. UTILITIES USE THEIR COMMUNICATION NETWORKS FOR COMMISSION CRITICAL FUNCTION. AS TECHNOLOGY EVOLVED OTHER UTILITY USE CASES WILL AS WELL. IN FACT THESE NETWORKS HAVE TRULY MODERNIZED THE GRID SINCE THE 1980S WHEN DIGITAL COMMUNICATIONS WERE REVOLUTIONIZED. ENABLING THESE LIKE SCADA TO BE COMMON PLACE. IF UTILITIES CONTROL THESE VITAL COMMUNICATIONS NETWORKS WHY DO WE ALWAYS HERE ABOUT THE *EURPT DEPENDENCY BETWEEN THE COMMUNICATIONS AND LEC SUCCESSORS. UTILITIES STILL RELY ON COMMERCIAL NETWORKS FOR SOME OF THEIR FUNCTIONS LIKE THEIR OUTWARD FACING INTERNET, SURPRISE TELEPHONES, ET CETERA. WE BELIEVE IN COMBINATION OF PRIVATE AND COMMERCIAL NETWORKS WILL GOVERN UTILITY COMMUNICATION NETWORK INTO THE CENTER BUT THE CENTER OF THE THEN DIAGRAM WHERE THE OVERLAP LIES WILL GET BIGGER AS YOUTILITY COMMUNICATIONS NEEDS INCREASE. GIVEN THIS CONTEXT, I APPRECIATE THE LEADERSHIP FERC HAS TAKEN TO BETTER UNDERSTAND THESE ISSUES. BECAUSE THE SEC GOVERNS COMMUNICATIONS POLICY, UTC IS CONCERNED THE AGENCY IS IT NOT CONSIDER THE SPECIAL RELIABILITY AND RESILIENCYS OF UTILITY. MUCH OF THE REST OF THE FEDERAL GOVERNMENT, FERC, DOE, WHITE HOUSE, CONGRESS CARE DEEPLY ABOUT SUCH MATTERS AND WORK CLOSELY WITH OUR SECTOR TO IMPROVE RESTORATION AFTER MAJOR STORMS, ENHANCE SITUATIONAL AWARENESS AND PLAN FOR UNEXPECTED EVENTS. I DON'T BELIEVE THE SAME FOCUS CURRENTLY EXISTS AT THE FCC. FOR EXAMPLE IN A CURRENT PROCEEDING JUST MENTIONED RELATED TO A CRITICAL WIRELESS SPECTRUM BAND, THE SIGNATURES GIGA HERTZ BAND, THE FCC IGNORED COMMENTS BY FIRST RESPONDERS AND RAILROADS AND OTHERS TO RESERVE THIS BAND FOR LICENSED USE. MANY UTILITIES USE THIS BAND FOR COMMISSION CRITICAL COMMUNICATIONS ON THE BULK POWER SYSTEM. LICENSED USE DOES NOT GUARANTEE INTERFERENCE FREE SPECTRUM ACCESS BUT IT INSURES ROBUST MITIGATION MEASURES FOR SUCH INTERFERENCE WHEN DETECTED, OPENING THE BANDS UNLICENSED USE BASED ON UNTESTED TECHNOLOGY IS AN INTOLERABLE RISK FOR UTILITIES IN OTHER WORDS, FERC WITH COULD WEIGH ON THIS EXPECTATION. BEYOND THIS ISSUE WE HOPE FERC WILL TAKE A LEADERSHIP ROLE IN ENGAGING WITH THE FCC TO IMPROVE CROSS SECTOROSH CLINICAL GENETICSINAL AWARENESS. FOR OUR PART IT WILL CONTINUE TO ENGAGE WITH THE COMMUNICATION SECTOR, AT THE END OF THE DAY, THE SMART ECONOMY WOULD NOT EXIST WITHOUT ELECTRICITY. BECAUSE COMMUNICATIONS NETWORKS REQUIRE POWERS TO OPERATE, AS SUCH, SHOULDN'T INSURING RELIABLE ELECTRICITY BE A CORNERSTONE OF COMMUNICATION POLICY. GOOD AFTERNOON, MR. CHAIRMAN, COMMISSIONERS, COMMISSIONER STAFF I'M JOHN MOREEN O, VICE PRESIDENT TECHNOLOGY AT CTIA. AND ON BEHALF OF OUR COMPANIES THROUGHOUT THE WIRELESS INDUSTRY, CTIA APPRECIATES THE OPPORTUNITY TO SHARE IN THIS CONFERENCE TODAY AND SHARE OUR NEXT GENERATION OF WIRELESS TECHNOLOGY 5G. WE ARE OPTIMISTIC ABOUT THE 5G FUTURE AND I LOOK FORWARD TO TALKING ABOUT TIEBREAKERS G'S REVOLUTIONARY CAPABILITY AND RELIABILITY, AND A ULS LOOK FORWARD ABOUT HOW IT WILL IMPACT THE SECTIONAL ANALYSIS OVERLAPPING EMPLOY CTI WELCOMES THE ENGAGEMENT ON THESE TOPICS WITH THE FCC, WITH THE WIRELESS INDUSTRY AND LOOK FORWARD TO ENHANCED COLLABORATION BETWEEN THE WIRELESS ENERGY AND THE ENERGY SECTOR AS MENTIONED EARLIER. TODAY, WIRELESS PLAYS A PIVOTAL ROLE IN HOW MANNERS LIVE, WO, AND SPEND THEIR FREE TIME. AND YET, 5G WILL HAVE AN EVEN BIGGER IMPACT FOR AMERICAN CONSUMERS IN THE U.S. ECONOMY. U.S. WIRELESS PROVIDERS LAUNCHED INITIAL 5G DEPLOYMENT LAST YEAR. AND WIRELESS COMPANIES ARE EXPECTED TO INVEST 275 BILLION TO BUILD OUT WIRELESS NETWORKS 5G NETWORKS OVER THE NEXT SEVERAL YEARS CREATING 3 MILLION NEW JOBS AND ADDING 500 BILLION TO THE U.S. ECONOMY. 5G OFFERS MANY ADVANTAGES OVER 4G, INCLUDING HIGHER CAPACITY, LOWER LATENCY, AND HIGHER ABILITY AND BETTER SECURITY, 5G WILL SUPPORT A HUNDRED TIMES MORE DEVICES, WE WILL BE UP TO A HUNDRED TIMES FASTER AND WILL BE FIVE TIMES MORE RESPONSIVE THAN EXISTING WIRELESS TECHNOLOGIES FOR THE ENERGY SECTOR, 5G TECHNOLOGIES WILL ENABLE SENSORS TO MEASURE THE LEVEL OF ENERGY OUTPUT AND REPORT OUTCONGRESSMANSY--SPECTRUM LICENSED FOR USE, GIVING THE LICENSE THE ABILITY TO FREELYY INNOVATE AND RESPOND WITH NEW ECNOLOGYS. NOW, WE CAN HARDLY TURN ON THE NEWS TODAY WITHOUT HEARING ABOUT 5G SECURITY. THE IMPORTANCE OF SECURING THE WIRELESS TECHNOLOGY SUPPLY CHAIN CANNOT BE OVERSTATED BUT IT IS IMPORTANT TO NOTE THAT SECURITY IS THE DNA OF 5G. 5G IS THE MOST ADVANCED SECURED TECHNOLOGY TO DATE. CTI AND MEMBERS ARE ENGAGED ON STANDARDS FOR BODIES AND WIRELESS PROVIDERS ACTIVE AND STAKEHOLDERS IN ADVANCING THE CYBERSECURITY FRAMEWORK ACROSS OUR INDUSTRY. FINALLY, THE WIRELESS INDUSTRY IS FIRMLY COMMITTED TO STRONG ROBUST WIRELESS RESILIENCY AND RECOVERY EFFORTS. WE KNOW THAT IN THE FACE OF DISASTERS AND EMERGENCIES CONSUMERS AND INDUSTRY DEPEND ON MOBILE WIRELESS SERVICES MORE THAN EVER. CTI MEMBERS REMAIN FOCUSED ON BUILDING INCREASINGLY RESILIENT NETWORKS AND EXHILARATING THE TIME LINE FOR SERVICES IMPACT BIDE A DISASTER OR EMERGENCY. AT THE SAME TIME, THERE IS MORE WORK TO BE DONE AND THAT ENCLUEDS ENHANCED COORDINATION BETWEEN WIRELESS AND UTILITY STAKEHOLDER BEFORE, DURING AND AFTER DISASTER EVENTS. WE LOOK FORWARD TO CONTINUING THE DIALOGUE AND CTI WELCOMINGS INPUT ON THIS FRONT. KREBS CYCLE, TI IS OPTIMISTIC ABOUT THE 5G FUTURE AND WE LOOK TO ENHANCE COLLABORATION IN THE ENERGY SECTOR, I WILL BE HAPPY TO ANSWER QUESTIONS. THANK YOU.

CHAIRMAN CHATTERGEE COMMISSIONERS, STAFF, AND I'M JOHN KUZEN I'M HERE ON BEHALF OF QUALCOMM AN AMERICAN COMPANY FOUNDED MORE THAN THREE DECADES AGO, WE EMPLOY 30,000 PEOPLE WORLD WIDE AND HAS GROWN RAPIDLY ALONG WITH THE MOBILE PHONE INDUSTRY. I BELIEVE THIS IS THE FIRST TIME QUALCOMM HAS TESTIFIED BEFORE THIS COMMISSION SO I WOULD LIKE TO PROVIDE A BRIEF OVERVIEW OF OUR COMPANY. WE ARE THE LEADING SUPPLIER OF MOBILE COMMUNICATIONS CHIPS FOR SMART PHONES AND OTHER WIRELESS DEVICES AND THE LEADING INVENTOR AND LICENSER OF NEW WIRELESS TECHNOLOGY. WE SPEND OVER 20% OF OUR REVENUES ON ON R&D. THESE MASSIVE EXPENDITURES HAVE LED TO MANY TRANSFORMATIVE INVENTIONS INCLUDING A BROAD ARRAY OF MOBILE INNOVATIONS RELATING TO 5G. THE TECHNOLOGIES WE'VE DEVELOPED FROM TWO G ALL THE WAY TO 5G, AND THE CHIPS WE DESIGNED TO SUPPORT THOSE TECHNOLOGIES DEPEND ON ONE KEY INPUT THAT THE FEDERAL GOVERNMENT CONTROL. SPECTRUM, QUALCOMM HAS BEEN AN ACTIVE PARTICIPANT IN THE EFFORTS BY THE FCC AND OPENING NEW BANDS FOR TECHNOLOGY. SUCH AS 5G AS WELL AS THE LATEST VERSION OF WIFI. THIS INCLUDES NEW LICENSED USE SPECTRUM, NEW UNLICENSED SPECTRUM AND NEW SHARED SPECTRUM OPPORTUNITIES IN LOW BAND BELOW ONE GIGA HERTZ, MIDBAND FROM ONE TO SEVEN GIGA HERTZ AS WELL AS HIGH BAND ABOVE 24 GIGA HERTZ AND THAT UNTIL 5G WAS DEVELOPED HAD NEVER BEEN USED FOR MOBILE COMMUNICATION. ONE OF THE BANDS THAT THE FCC PROPOSED FOR POINT TO POINT FIXED LINK AND NEW 5G AND WIFI UNLICENSED DEVICES IS THE SIX GIGA HERTZ BAND. THIS BAND IS HEAVILY USED BY TENS OF THOUSANDS OF FIXED LINKS. MOST OF THE WHICH OPERATE VIA DIRECT LINE OF SIGHT, POINT TO POINT USING ANTENNAS INSTALLED ON TOP OF BUILDINGS AND MOUNTAINS. QUALCOMM AND OTHER TECHNOLOGIES ARE WORKING WITH THE FCC, AS WELL AS INCUP BENT FIXED USERS OF THE BAND INCLUDING UTC AND ITS MEMBERS TO ALLOW NEW LOW POWER BY FULLY PROTECTING INCUMBENT USERS AND ALLOWING BOTH TO CONTINUE DEPLOYING SERVICES IN THE BAND. THE SIX GIGA HERTZ BAND SUPPORTS COMMUNICATIONS NEEDS OF VERY DIVERSE INDUSTRY. ENERGY UTILITY, PUBLIC SAFETY, WIRELESS PROVIDERS, CABLE PROVIDERS, THESE COMMUNICATIONS ARE CRITICALLY IMPORTANT AND WE WOULD NOT BE SUPPORTING UNLICENSED USE OF THIS BAND IF WE DID NOT BELIEVE IT COULD NOT BE DONE WITHOUT PROTECTING THESE CURRENT INDUM BENT USERS BECAUSE THE INCUMBENT LENGTHS ARE FIXED AND THEIR OPERATIONAL PARAMETERS ARE IN A PUBLIC FCC DATABASE PROTECT THINK THEM IS RELATIVELY STRAIGHT FORWARD. THE DICKS GIGA HERTZ BAND PROVIDES TECHNOLOGY TO SUPPORT NEW SERVICES AND APPLICATIONS FOR THESE INDUM BENT APPLICATION UTILES AND OTHER INDUSTRIES AS WELL AS MANY OTHER AMERICAN CONSUMERS. 5G TECHNOLOGY WILL USE ALL AVAILABLE SPECTRUM TO DELIVER A NEW LEVEL OF WIRELESS CONNECTIVITY NOT POSSIBLE WITH EARLIER TECHNOLOGY GENERATIONS. SPEEDS MORE THAN A HUNDRED TIMINGS FASTER WITH GREATLY IMPROVED RELIABILITY AND LATENCY AS LOW AS ONE MILLI SECOND. TO SUPPORT NEW APPLICATIONS AND SERVICES INCLUDING WITHIN UTILITY PLANTS. INDUSTRIAL AUTOMATION USERS IN PARTICULAR ARE VERY INTERESTED IN THIS PRODUCTIVITY IMPROVEMENT AREA. EXPENSIVE CABLING CAN BE REPLACED WITH WIRELESS CONNECTIVITY AND ROUGH ATOM VIED EASY RECONFIGURURE ABILITY INSIDE OF THE PLANT FOR THE UTILITY TRANSMISSION AND DISTRIBUTION PLANT, TRIBUTED CONTROL AND REMOTE MONITORING OF ASSETTEDS WILL BENEFIT FROM 5G CONNECTIVITY AND FINALLY FOR SMART METERS, HIGHLY RELIABLE 5G BASED MACHINE TO MACHINE CONNECTIVITY WILL ALLOW LARGE NUMBERS OF CUSTOMER METERS TO BE CONNECTED. THANK YOU FOR YOUR TIME, I LOOK FORWARD TO YOUR QUESTIONS.

GOOD AFTERNOON I AM STEVE LOWE AND I LEAD AT&T'S ADVANCE SMART SOLUTIONS TEAM, I HAVE BEEN WITH AT&T FOR TEN YEARS AND TEN OF THAT HAS BEEN FOCUSED ON COMMUNICATIONS BEFORE THEY WAS AMERICAN ELECTRIC POWER WITH THE DISTRIBUTION SIDE OF THE BUSINESS, IT IS AN HONOR TO APPEAR ON THE PANEL RELATING TO COMMUNICATIONS AND TECHNOLOGYOT NEW GRID. UTILITY VS LONG SOUGHT TO ACQUIRE DEDICATED PRIVATE, LICENSED BROAD BAND SPECTRUMS TO HELP SUPPORT NEEDS FOR DEDICATED HIGH PERFORMANCE WIRELESS COMMUNICATION DATA NETWORKS THIS, LEFT UTILITIES USING PUBLIC NETWORKS AND SHARED UNLICENSED SPECTRUM TO MEET DATA NEEDS ISSUES THE RESULT, OPERATIONAL INEFFICIENCIES AND, LOW PERFORMANCE AND INCREASED EXPENSES. AS A CONSEQUENCE, MANY UTILITY VS A MULTITUDE OF PURPOSE BUILT AREA NETWORKS SUPPORTING OPERATIONS WITH THEIR OWN UNIQUE EQUIPMENT, MANAGEMENT TOOLS AND LIFE CYCLE SUPPORT REQUIREMENTS. NEW GRID APPLICATIONS INCLUDING DISTRIBUTED GENERATION MANAGEMENT ARE DRIVING CRITICAL GRID COMMUNICATION REQUIREMENTS FOR ESSENTIAL CONTROL, RELIABILITY AND SECURITY THAT CURRENT PURPOSE BUILT, TYPICAL CANNOT ADDRESS. AT&T'S PRIVATE LTE NETWORK UTILITY ALLOWS UTILITIES TO BUILD ON, AND OPERATE THEIR OWN LTE OF THE NETWORK THAT CAN BE USED IF ARE A MULTITUDE OF UTILITY GRID APPLICATION, THIS OPENS GREAT EXCITING COMMUNICATIONS STRATEGIES BY UTILIZING STANDARDS BASED TECHNOLOGY THAT IS READY FOR MISSION CRITICAL APPLICATION DUTY. THIS SOLUTION OFFERS PROVEN LARGE NETWORK CAPABILITY, SCALABILITY AND LONGEVITY TO MEET UTILITIES OPERATION NEEDS WHILE ALLOWING THEM TO BENEFIT THE NETWORKS, UTILITIES ARE A CRITICAL INFRASTRUCTURE INDUSTRY, OUR CHALLENGE TO IMPROVE SERVICE DELIVERY AND ADDRESS INCREASING SECURITY THE--THISS COMPOUNDING THESE ARE ARE THE PRESSURES FROM REGULATORY AGENCY TO STREAMLINE OPERATIONS AND REDUCE CALLS. TO OVERCOME THESE CHALLENGES UTILITIES REQUIRE GREATER REMOTE MONITORING IN THE CONTROL AND OPERATION, AS A RESULT THEY ARE LOOKING TO LEVERAGE IOT COMMUNICATIONS TECHNOLOGY, TO PROVIDE THESE INSIGHTS TO INCREASE AUTOMATION OF THEIR OPERATION. IOT COMMUNICATIONS TECHNOLOGY ENABLING CONNECTIVITY TO APPLICATIONS LIKE DEMAND RESPONSE, DISTRIBUTION AUTOMATION, LOAD BALANCING SMART MEETS AND SMART GRID OPERATIONS WITH THE PRIVATE NETWORK UTILITY IS ABLE TO PRIORITIZE USAGE AND HAVE A LEVEL OF VISIBILITY AND CONTROL. ENABLING REALTIME DECISIONGRID CONFIGURURATION, OUTAGE RESTORATION, SYSTEM MAINTENANCE AND MORE. USING NETWORKS AND LICENSED WOEURLESS SOLUTIONS CAN CREATE VOWEL FERRABILITYS IN THE APPLICATION AND ARE SUSCEPTIBLE TO OUTAGES CONGESTION AND INTERFERENCE. THE DREAM OF UTILITIES OPENING A HIGHLY MULTIPLE APPLICATION OF THE NETWORK IS A REALITY. AT&T'S PRIVATE LTE UTILITY TO BRING SPECTRUM EQUIPMENT AND SERVICES TOGETHER INTO A SINGLE OFFERING WOULD SEAMLESSLY UNLIMITED OPPORTUNITIES ON BEHALF OF AT&T AND THE IOT SMART CITIES ADVANCE SOLUTIONS TEAM WE APPRECIATE THE OPPORTUNITY TO APPEAR BEFORE YOU AND LOOK FORWARD TO TODAY'S DISCUSSION ON THE CRITICAL TOPIC OF COMMUNICATIONS FOR UTILITIES.

THANK YOU ALL. I WILL TURN TO MY COLLEAGUES COMMISSIONER GLICK TO KICK US OFF.

THANK YOU MR. CHAIRMAN. AND THANK YOU VERY MUCH FOR BEING FLEXIBILITY ON THE TIMING. YOU KNOW THIS ISSUE STRIKES ME AS WASHINGTON D. C. FEDERAL GOVERNMENT ISSUE WHERE THERE'S A LIMITED SUPPLY OF SOMETHING AND THE GOVERNMENT HAS TO FIGURE OUT HOW TO ALLOCATE IT TO COMPETING GROUPS IN THE DIFFERENT USE OF THAT THING. SO I'M CURIOUS THE FCC WILL MAKE THE DECISION ABOUT THE USE OF THE SIX GIGA HERTZ BAND, WHAT'S THE STANDARD THEY USE, IS IT A PUBLIC INTEREST STANDARD? IS THAT IT?

WANT ME TO GO FIRST?

AT ITS CORE IT'S THE PUBLIC INTEREST STANDARD, RIGHT AND THEN UNDERPINNING THAT, IS A BODY OF [INDISCERNIBLE]. SO WITH REGARD IN PARTICULAR, THE FCC IS NOT GOING TO MOVE FORWARD UNTIL IT IS CONVINCED THAT THE INCUMBENT USERS WILL NOT BE IMPACTED. THEY WILL NOT MOVE FORWARD UNLESS THEY'RE CONVINCED THAT THEY WILL NOT BE HARMFUL INTERFERENCE TO THE INCUMBENT LENGTHS SO THAT'S THE THRESHOLD QUESTION. AND YOU KNOW ON BEHALF OF QUALLCOMM, AND SEVERAL COMPANIES THAT WE'RE WORKING WITH, THAT ARE HOPE EMPLOY THAT THEY WILL BE OPENED UP FOR LICENSED USE, WE'RE WORKING WITH THE FCC, WE'RE WORKING WITH THE UTILITIES, WE'RE WORKING WITH WIRELESS CARRIERS WHO ARE INCUMBENT IN THE BAND, CABLE PROVIDERS TO HELP THEM UNDERSTAND THE VARIOUS INTERFERENCE SCENARIOS, AND YOU KNOW, BASICALLY TO MAKE SURE THAT INTERFERENCE DOES NOT OCCUR AND IT'S IMPORTANT TO RECOGNIZE HERE, THAT ALL OF US HAVE THE SAME COMMON GOAL. WE DO NOT--THOSE OF US IN FAVOR OF OPENING UP THE BAND FOR UNLICENSED HAVE THE SAME GOAL AS ALL OF THE INDUM BENTS, UTILITY, CABLE PROVIDERS BECAUSE LOOK, IT'S HARD TO IMAGINE BUT WE'RE STILL AT A VERY EARLY STAGE IN THE INFORMATION AGE. SO IF A BAND IS NOT OPENED PROPERLY, RIGHT, IF THERE IS INTERFERENCE, IT'S NOT GOING TO BODE WELL FOR THAT BAND OPENING, FUTURE BANDS OPENING AND IT'S IN ALL OF OUR INTERESTS TO MAKE SURE, THAT WHEN WE MOVE FORWARD IT'S DONE IN A CAREFUL CONSIDERED WAY.

SO THAT'S GREAT TO HEAR AND I THINK ONE OF THE THINGS THAT I THINK I WOULD POINT OUT IS THAT WE REACHED OUT AS WITH QUALCOMM ONCE IT'S BEEN INITIATED TO SEE WHAT THE TESTING, YOU KNOW THE MITIGATION METHODOLOGY THAT THEY'RE PROPOSING IS. WE HAVE NOT BEEN INVOLVED PRIOR TO THE PROPOSED RULE MAKING BEING RELEASED IN ANY DISCUSSIONS AROUND WHAT THIS INTERFERENCE MITIGATION WOULD BE. SO WE DID REACH OUT AND WE'RE HAVING REALLY GOOD DISCUSSIONS, I THINK NOW WITH QUALCOMM AND OTHERS WHO ARE INTERESTED IN OPENING THE UNLICENSED BAND. AND THAT'S ALL WELL AND GOOD BUT TO DATE WE'RE NOT CONVINCE THAD THIS TECHNOLOGY WILL PROVIDE THE *EURPT FER ENSEL MITIGATION THAT IT'S BEING--THAT IT'S BEING--SAID IT WOULD. SO WHILE WE ALL HAVE PERHAPS THE SAME GOAL THAT THE PROCESS SO FAR HAS BEEN ONE THAT'S PRESUPPOSED, THE OUTCOME SEEMS TO BE PRESUPPOSED AND THAT IS ECHOES BY COMMENTS BY THE COMMISSIONERS AND PUBLIC FORUMS SO WHAT WE WOULD ASK GOING FORWARD IS ANY IT'S IN THE SIX BIGGA HERTZ BANDS OR OTHER BANDS THAT ARE PROPOSED TO BE OPENED FOR UNLICENSED USE IN THE NAME OF 5G OR OTHER THINGS IS THAT ON THE FRONT END, THAT THAT OUTREACH OCCURS ABOUT THESE TYPES OF TECHNOLOGIES THAT ARE NEW AND PERHAPS IN TEXAS. IN OUR EXPERIENCE BACK TO YOUR QUESTION AROUND PROCESS OF THE FCC AND TYPICALLY THE FCCONSIDERING DOES REQUIRE TESTING AND THERE'S AN ELEMENT OF TESTING INVOLVED WHEN RULE MAKE SUGGEST APPROVED SO WE WOULD ASK THAT YOU KNOW IF THEY'RE INTENT ON GOING FORWARD, THAT WE WOULD ACTUALLY FIELD TEST NOT JUST--NOT JUST TEST IN THE LAB AND I WOULD ARGUE THAT THIS IS MORE COMPLICATED THAN JUST PULLING DOWN DAT FROM A DATABASE. SO THERE ARE ISSUES WITH WIRELESS SERVICE THAT ARE VERY MUCH FIELD BASED, SO WE TEST THESE TYPES OF TECHNOLOGY--THIS TECHNOLOGY IN PARTICULAR TO DETERMINE WHAT THE ACTUAL MITIGATION MEASURES ARE, BEFORE WE MOVE FORWARD ON THE RULE.

WHAT'S THE RESISTANCE TO FIELD TESTING.

NONE.

NONE.

WE'RE HAPPY AND IT'S WORKING WITH THE UTC,--MEMBERS, SORRY AND MANY OTHERS, YOU KNOW WHO HAVE ASKED FOR YOU KNOW MEETINGS ANALYSIS AND SO FORTH.

GETTING BACK TO THIS.

SO IN TERMS OF IF THERE'S NO RESISTANCE IS IT A TIME ISSUE,.

YEAH IT'S A TIME ISSUE WHAT WE HEARD AGAIN IN PUBLIC STATEMENT SYSTEM THAT THIS IS RULE MAKING BY THE FOURTH QUARTER OF THIS YEAR AND AGAIN, THE OUTREACH OCCURS AFTER THE FACT IN TERMS OF THE PROCESS, SO, I MEAN, THIS--THE FIELD TESTING IS NOT SIMPLE, IT'S NOT--IT DOESN'T HAPPEN, WITH THE SNAP OF A FINGER. SOMETIMES IT TAKES MONTHS. THAT'S REALLY THE ISSUE. SO WE'RE HAPPY TO HEAR THAT FIELD TESTING WILL BE SOMETHING THAT QUALCOMM IS OTHERS MIGHT BE OPEN TOO BUT WE HAVE TO WORK WITH THE SEC TO THEN SEE IF THEIR TIMELINE CAN BE EXTENDED.

SO FOLKS ON THIS, MR. BRUMMOND, HOW ARE YOU ENGAGING NERC WITH THIS? ARE THEY CONCERNED?

YOU KNOW I DON'T--I'M NOT AWARE OF EXACTLY HOW WE'RE WORKING WITH NERC ON THIS. OF COURSE WE'RE WORKING WITH UTC. WE OF COURSE HAVE THE NERC STANDARDS IN OUR MIND WHEN WE THINK ABOUT THESE THINGS AS I NOTED, I WOULD ALSO NOTE ON THE FIELD TEST, YOU KNOW WHEN THINGS ARE FIELD TESTED FROM OUR PERSPECTIVE, A LOT OF OUR EVENTS, A LOT OF BAD WEATHER EVENTS RIGHT? SO THINGS NEED TO WORK WHEN CONDITIONS ARE THE WORST AND A LOT OF TIMES THERE'S SEASONALITY, SO FIELD TESTED IN THE SUMMER, IN THE WINTER WHEN IT'S RAINY, WHEN IT'S WINDY, FROM OUR PERSPECTIVE WE WOULD HOPE THAT ALL OF THOSE THINGS WOULD BE TAKEN INTO,A COUNT. SO, YOU KNOW EXCEPT FOR THE FACT THAT I GOT TO WE HAVE NOT ENGAGED THEM ON FOR THE ISSUE WITH THESE CONVERSATIONS WITH FREQUENTLY ON CYBERSECURITY MATTERS AND OTHERS.

ONE LAST QUESTION, SO WITH REGARD TO--JUST TO BE CLEAR WHAT YOU'RE ASKING, A LOT OF THAT TESTIMONY, WITH THE ENGAGEMENT, AND DIALOGUE WITH THE FCCAND I KNOW WE TALKED ABOUT THIS IN THE PAST, YOU ARE ASKING THAT FERC ASK TO DELAY TESTING IN THE THE FIELD TESTING IS DONE? IS.

THAT WOULD BE GREAT ASK. OUR ULTIMATE GOAL IS REALLY THAT THIS BAND SHOULD BE RESERVED FOR LICENSED USE BUT IF THE FCC AS IT SEEMS IS INTENT TO OPEN UP THE BAND, THAT WOULD BE AN ACCEPTABLE OUTCOME IS THAT ACTUALLY GET SOME TESTING DONE OF THIS TECHNOLOGY WHICH IS CALLED ASC, AND SEE IF IT ACTUALLY WORKS IN PRACTICE AND THEN BRING THAT BACK TO THE FCC AND SAY EITHER IT DOESN'T WORK OR IT DOES WORK OR WE NEED MORE TIME TO MODIFY IT TO MAKE IT WORK. SO YES, I THINK FERC, IF FERC WOULD BE WILLING TO MAKE THAT REQUEST, THAT WOULD BE A GREAT, GREAT THING. THAT WOULD BE GREATLY APPRECIATED.

YES AND IN ANOTHER PROCEEDING, WE HAVE BASICALLY THE OPPOSITE OCCURRING. IN THE 900 MEGAHERTZ PROCEEDING, THE RELATIVELY UNDERCURTAILED TILLIZED LOW BANDS WE TALKED ABOUT, WE TALKED ABOUT LOW AND MIDAND HIGH. THIS IS A LOW BAND OPPORTUNITY THAT WE REQUEST FERC WORK WITH FCC TO SPEED UP THE PROCESS SO UTILITIES COULD USE IT BUILD PRIVATE LTE NETWORKS, IT IS THE FOUNDATION LAYER THAT GETS THEM THE COVERAGE THEY NEED, PERFORMANCE THEY NEED AND MOST IMPORTANTLY SECURITY THEY NEED. LATER ON IF YOU COME BACK AND BUILD OVER THE TOP OF THAT WITH THE MIDBANDS AND HIGHER PWABDS BUT IT STARTSA THE A FOUNDATIONAL LEVEL. SO IN OUR CASE, IT'S REALLY THE OPPOSITE OF THE SIX GIGA HERTZ.

JUST A QUICK QUESTION, MR. LOWE, BECAUSE WE'RE THERE NOW, DO YOU HAVE ANY CONCERNS WITH US, THE FERC ASKING THE FCC TO CONSIDER THE QUESTION, BUT ALSO THE SEPARATE QUESTION FOR THE [INDISCERNIBLE]?

I HAVE NO POSITION WITH REGARD TO [INDISCERNIBLE]. BUT THE REQUEST TO TEST--TESTING IS DEFINITELY WITHIN THE REALM OF SOMETHING THAT SHOULD BE DONE HERE. BUT I CAUTION WITH THE FACT OF TESTING TO YOU KNOW FOREVER AND EVER OF THIS SAMPLE AND THIS CONDITION, AND SO FORTH. I THINK LIMITED FIELD TESTING TO CONFIRM VIABILITY OF SHARING IS PERFECTLY WITHIN THE REALM OF WHAT SHOULD BE CONSIDERED AND WHAT WILL BE DONE BUT AGAIN, I CAUTION AGAINST HAVING AN 18 POINT TEST PLAN THAT TAKES ONE YEAR TO DEFINE 18 MONTHS TO CARRY OUT, ANOTHER YEAR TO RIGHT A REPORT AND WE'RE IN 2024, THAT'S WHAT I CAUTION AGAINST.

THANK YOU.

THANK YOU ALL FOR COMING TO THE COMMISSION TO TALK ABOUT THIS REALLY INSIGHTFUL AND IMPORTANT DISCUSSION AND TESTIMONY, AT A CONCEPTIONAL LEVEL, I GET IT WHY *EURBT FER ENSEL IN THE SIX GIGA HERTZ IS PROBLEMATIC. I WOULD LIKE TO GET INTO EXAMPLES SO IF WE COULD DRILL DOWN ON WHAT THE LIABILITY IMPACTS COULD BE, MR. BRUMMOND, IN YOUR TESTIMONY, YOU TALK ABOUT USING A GENERATOR TO SECOND TO THE MISO EVERY TWO-SECONDS IF THERE WERE *EURBT FER ENSEL IN THE SIX GIGA HERTZ PECK RUM HOW WOULD IT IMPACT THOSE GENERATORS? WOULD IT BE AN OCCASIONALLY UNSUCCESSFUL TRANSMATION OR WOULD THE IMPACTS BE MORE SIGNIFICANT?

FROM WHAT I UNDERSTAND IF THERE'S ENOUGH INTERFERENCE, IT WOULD BE SIGNIFICANT. WE COULD LOSE COMMUNICATIONS. I WOULD HOPE IF THIS HAPPENS WE WILL HAVE TO WATCH THAT CAREFULLY, I HOPE THAT'S SOMETHING WE WOULD HAVE TO GET AHOLD OF, GET AHEAD OF AND TRY AND FIGURE OUT AWAY AROUND IT. IT'S AN UNACCEPTABLE CONDITION FOR US TO HAVE THOSE SIGNALS FRANKLY INTERFERED WITH TO THE POINT THAT THEY CAN'T GET THROUGH SO THAT WOULD HAVE TO BE SOMETHING WE WOULD HAVE TO WATCH CAREFULLY, BECAUSE WE WOULD WANT TO GET AHEAD OF IT. BECAUSE THESE ARE COMMISSION CRITICAL COMMUNICATIONS FOR US AND SO WE NEED ON GET AHEAD OF THISEM AND REACT TO THEM BEFORE THEY HAPPEN AS QUICK AS POSSIBLE.

ANY OTHERS WITH THOUGHTS ON THAT?

LET ME QUICKLY CLARIFY SOMETHING ABOUT THE SIX GIGA HERTZ BAND VERSUS THE OTHER BANDS, YOU HEARD ABOUT THE 2.3, THE 900 AND SOME OTHER SPECTRUMS. SO, SIX GIGA HERTZ HAS UNIQUE POPIGATION AND QUALITIES SO IT'S NOT EASILY DUPLICATED ELSEWHERE, SOMEWHAT YEARS AGO UTILITIES WERE FORCED OUT OF THE TWO GIGA HERTZ BANDS WHICH HAD SIMILAR QUALITY AND RELIABILITY. SO BASICALLY IT'S ALMOST LIKE A PIPE. IT CAN ALMOST TAKE THE PLACE OF A WIRE LINE, SO A FIBER LINE, SO IT'S A POINT TO POINT SITUATION, MICROWAVE SITUATION, SO CAN YOU DUPLICATE WIRE LINE CAPABILITIES WITH THIS MICROWAVE CAPABILITY, SO IF YOU'RE INTERESTING AND IN A SITUATION WHERE YOU CAN'T LAY WIRE LINE, CAN YOU USE THIS AS A REPLACEMENT THAT. IS NOT TRUE OF SOME OF THESE OTHER BANDS THAT WHILE THERE'S GREAT INTEREST IN THEM IN THE 900 FOR SOME AND THE TWO PASSPORT THREE, THERE'S USE FOR DIFFERENT TYPE OF APPLICATIONS FOR BROAD BAND LTE WHICH IS NOT FOR THIS MISSION CRITICAL APPLICATION, I WANT TO BE CLEAR ABOUT THAT. IT'S NOT SOMETHING SO WE CAN'T EASILY GO ANYWHERE ELSE. IF THESE AREN'T WORKING IN THE SCENARIO THAT JP MENTIONED, WHAT ARE OUR OPTIONS AT THAT POINT? THEY'RE NOT VERY GREAT. I JUST WANT TO BE CLEAR ABOUT THAT.

YOU MENTIONED THAT IN YOUR TESTIMONY, THE SIGNIFICANT BURTEN BEING IMPOSED THAT THEY'RE REQUIRED TO SIX BANDS OUT OF SIX GIGA HERTZ CAN YOU ELABORATE ON WHAT THE IMPACTS AND UTILITY CUSTOMERS WOULD BE IF THEY WERE FORCED TO SWITCH BANDS?

THERE'S NOT A LOT OF OPTIONS SO YOU'RE TAKING A TOOL OUT OF OUR TOOL BOX, A RELIABILITY TOOL. SOPHISTICATEDY YOU KNOW WE CREATE REDUNDANCY NEGLIGENCE OUR SYSTEM AND IT'S THE SAME THING WITH COMMUNICATIONS REDUNDANCY SO THE CHOICE IN SOME CASES WOULD BE TO TRY TO LAY FIBER LINES BUT THAT IS LIMITED IN CERTAIN AREAS, FOR EXAMPLE, IN THE WEST WHEN THEY NEEDED TO DO THAT OVER FEDERAL LAND OR WHEN THERE AREN'T RIGHTS OF WAY. SO THIS MICROWAVE TECHNOLOGY AGAIN IS A BACKBONE TYPE OF TECHNOLOGY THAT YOU REALLY CAN'T DUPLICATE AND WHAT MY UNDERSTANDING IS IN THE 5G REALM, THERE ARE OTHER BANDS THAT FOLKS COULD GO TO TO PROPAGATE THEIR WIRELESS TECHNOLOGIES AND 5G, MY BEDDING IS THAT THIS BAND IS ATTRACTIVE BECAUSE EQUIPMENT IS AVAILABLE AND THINGS LIKE THAT IT WAS LEGITIMATE. BUT THERE ARE OTHER PLACES THAT I CAN GO IF THEY NEED TO USE--TO HAVE 5G APPLICATIONS AND CAPABILITY, WE DON'T HAVE THAT OPTION, SO THAT IS IN KEEPING SO IN ADDITION TO THE STRANDED COST AND ALL THE THINGS THAT YOU CAN ENVISION WITH HAVING TO DO AWAY WITH EQUIPMENT THAT WE CAN'T USE BECAUSE WE CAN'T TOLERATE POTENTIAL INTERFERENCE, WHAT ARE THE OPTIONS THEN? SO AGAIN, LAYING FIBER MIGHT BE AN OPTION, MIGHT NOT. SO THEN DO WE JUST TAKE THE RISK THAT OUR COMMUNICATIONS GOING TO BE UNRELIABLE? SO IT'S JUST--IT SETS UP A VERY DIFFICULT SCENARIO FOR US.

THANK YOU FOR BEING HERE AND YOUR LEADERSHIP ON THIS ISSUE, OBVIOUSLY SPECTRUM AND ALREADY IMPORTANT TO UTILITIES WITH BUT WITH THE PROLIFERATION OF SMART METERS, DISTRIBUTED ENERGY RESOURCES AND OTHER DISTRIBUTED DEVICES I'M INTERESTED IN WHETHER AND HOW YOU ALL EXPECT THE USE OF SPECTRUM TO GROW AND CHANGE AND WHETHER THERE ARE COMMUNICATION ISSUES THAT WE MIGHT NEED TO BE MONITORING. MR. BRUMMOND WHO'S SOMEBODY WHO IS OPERATING, HAPPY TO TURN IT TO YOU AND TURN IT TO SPW-B ELSE WHO WANTS TO JUMP?

ABSOLUTELY. THERE ARE GENERAL THINGS, I'M THINKING OF AI, SIRI, WITH THE USE OF 5G, THERE'S A LIKELY SPECTRUM, WE'RE THINKING OF THAT BUT JUST MORE DIRECTLY INNER INDUSTRY. THERE ARE A NUMBER OF THINGS THAT WILL DRIVE THE NEED FOR MORE COMMUNICATION. AS YOU LOOK THERE'S A BIG CHANGE GOING FROM CENTRALIZED GENERATION TO DECENTRALIZED GENERATION AND WE'RE--GRAPPLING WITH THIS, MISO IS GRAPPLING WITH THIS AS WELL YOU KNOW TO THE EXTENT WE HAVE A SIGNIFICANT PORTION OF OUR GENERATION AS SOLAR GENERATORS DISTRIBUTED THROUGHOUT OUR NETWORK, WE'RE GOING TO NEED TO KNOW AS YOU KNOW THOSE ARE VARIABLE AND THOSE ARE NOT SOMETHING THAT ARE DISBATCHABLE, AT LEAST YOU CAN'T DISBATCH THEM ABOVE THE SOLAR CAPACITY AT ANY ONE TIME AND IT MAKES SENSE TO ME THAT WE WILL HAVE TO HAVE COMMONICATIONS AT A MINIMUM TO SUPERVISE LAWN MOWER'S GOING ON WITH THOSE BUT POTENTIALLY TO BE ABLE TO DISPATCH THEM. WIND CAN DISPATCH, CAN YOU DISPATCH A WIND UNIT DOWN TO CONTROL OUR SYSTEM. SO THAT'S POTENTIALLY A LOT OF NEW COMMUNICATION THAT COULD NEED TO OCCUR, YOU KNOW TODAY AND NOT A BIG ISSUE, FAST FORWARD TEN YEARS, THAT COULD BE A BIG DEAL WHERE YOU HAVE SOLAR PANELS, YOU LOOK AT ELECTRIC CARS, THAT'S ANOTHER HUGE RESOURCE POTENTIALLY FOR US. YOU KNOW I CAN ENVISION HAVING OUR CUSTOMERS HAVE THE OPTION THAT IF ENERGY MARKET HITS A CERTAIN PRICE, WE CAN BUY ENERGY FROM THEIR BATTERIES. AND USE THEM AS A VIRTUAL POWER PLANT AS YOU PROBABLY READ ABOUT. IF WE'RE GOING TO DO THAT, THOUGH, THAT'S A LOT OF COMMUNICATIONS, THAT'S A LOT OF ALL RIGHT, HOW MUCH ENERGY DO WE NEED, WHAT'S THE RIGHT PRICE, CALLING ON THOSE, SEEING WHAT THE RESPONSE IS BACK, THAT'S ALL OF THIS SCADA TYPE COMMUNICATIONS THAT I'M TALKING ABOUT, THE SECOND TO SECOND REALLY CONTROLLING THE FREQUENCY OF THE GRID. UPON SO IN MY MIND, I SEE THE NEED FOR THESE TYPES OF COMMUNICATIONS GROWING JUST INTERNALLY FOR OUR OWN NEEDS AND SOME OF THAT IS GOING TO BE FIBER, BUT, WE'RE IN A RURAL AREA IN WISCONSIN APPROXIMATE IN IOWA AND IT GETS TO BE--IT'S JUST TOUGH TO PUT A FIBER EVERYWHERE SEE YOU WILL BE RELYING ON WIRELESS COMMUNICATIONS IF ARE THAT AND THEY WILL BE CRITICAL COMMUNICATIONS FOR THOSE.

MAY I ADD COMMENTS TO THAT. IN AT&T EVERYTHING IS SIMILAR WHAT WE'RE EXPERIENCING IN THE IUT WORLD, IT'S EXPONENTIALLY GROWING WHEN I STARTED WORKING AT COMMUNICATIONS WITH UTILITIES BACK IN 2011, THERE WAS A LIMITED NUMBER OF DEVICES OUT IN THE FIELD BECAUSE PRIMEAR LE THEY WERE USING WIRE LINE TECHNOLOGY TO COMMUNICATE. SINCE THEN WE'VE SEEN A SIGNIFICANT GROWTH IN OUR COMMUNICATION REQUIREMENTS INCLUDING THE EIN, I METERS AND THEN WITH AMI METERS BEING THAT CONNECTIVITY TO THE BEYOND THE METER OR INTO THE HOME, YOU WILL AGAIN SEE A NEED FOR ADDITIONAL BAND WIDTH AND I THINK THE TECHNOLOGY IN MY STATEMENT TODAY THEY HAVE PURPOSE BUILT NETWORKS AND THE THEY SUPPORT ONE PURPOSE. NOW THEY NEED TO START LEVERAGING THESE NETWORKS TO BE ABLE TO SUPPORT ALL THE OTHER TECHNOLOGIES THAT CONSUMERS ARE DEMANDING TO BE ABLE TO DELIVER. THIS IS DISTRIBUTED GENERATION, ELECTRIC VEHICLES, COULD BE A LOT OF THINGS THAT ARE HAPPENING IN THE HOME. AS YOU LOOK AT THE GROWTH PATTERN THAT AT&T HAS FROM KNOW IUT PERSPECTIVE YOU WILL SEE SOMETHING SIMILAR TO THAT TRAJECTORY WITHIN THE UTILITY INDUSTRY SO THERE HAS TO BE A COMMUNICATIONS PLATFORM THAT SUPPORTS THAT. I DON'T REALLY HAVE A POSITION ON SIX GIGA HERTZ, I'M SURE AT&T DOES BUT NOT ME. I WOULD SAY THAT AT&T RECOGNIZES THE NUMBER OF DEVICES THAT UTILITIES ARE GOING IT NEED AND WE BUILD A PROGRAM TO BE ABLE TO SUPPORT IT AND USING OUR COMMERCIAL BAND THAT WE HAVE AVAILABLE TODAY AND WE'VE ALSO BEEN ABLE TO INCORPORATE UUTILITYS INTO THE FIRST NET PROGRAM AS AN EXTENDED PRIMARY USER AND THEN AS JOY MENTIONED IS THAT AT&T HAS A LINE TO WORK WITH THE FCC TO DEDICATE 2.3 GIGA HERTZ TO THE UTILITY INDUSTRY TO USE BY THEMSELVES WITH NO CONFLICT OR ANY INTERFERENCE OR ANYONE ELSE. SO I THINK THAT DEFINITELY EVERYBODY RECOGNIZED THAT THE GROWTH OF DEVICES, IT MIGHT BE THAT WE HEAR SOME UTILITIES PUTTING A POLE SENSOR ON ANY POLE AND WHEN YOU DO THAT YOU GO FROM THOUSANDS ON TO MILLIONS CONNECTIVITY AND YOU WILL NEED COMMUNICATION TOOLS.

MR. CHAIRMAN IF I MIGHT, ON BEHALF OF THE WIRELESS INDUSTRY, A COUPLE WILL PINTS I WOULD LIKE TO MAKE. THE INDUSTRY HAS GONE THROUGH [INDISCERNIBLE] WORKING WITH INDUM BENTS ON THE SIX GIGA HERTZ BAND TO INSURE NONINTERFERENCE SO THAT'S A NONISSUE FOR US AND CLEARLY WE'RE PREPARED TO CONSIDER WHATEVER IT TAKES TO EMBRACE THAT APPROACH BECAUSE THE WIRELESS INDUSTRY HAS BEEN AROUND FOR CLOSE TO FOUR DECADES AND ALMOST AS LONG AS I'VE BEEN IN THE INDUSTRY AND HAS ALWAYS OPERATE IN A NON*EURPT FERNESS BASES AND IT'S SOMETHING THAT THEY HAVE A GREAT DEAL OF EXPERIENCE WITH AS DOES THE FCC BECAUSE THE U.S. ALLOCATED WHEN SPECTRUM WAS ONE G, TWO G, THREE G, AND 4G AND 5G ARE COMING ALONG AND WE HAVE EXPERIENCE IN HOW DO YOU DEAL WITH THESE IN TERMS OF INCUMBENTS AND HOW DO YOU INSURE YOUY DEVIE THE BENEFITS OF NEW TECHNOLOGY, LEVERAGE THAT TECHNOLOGY FOR CONSUMERS FOR THE U.S. ECONOMY, FOR SECURITY AND RELIABILITY, BUT AT THE SAME TIME NOT STRAND A PIECE OF SPECTRUM AT SIX GIGA HERTZ OR ANY OTHER PARTICULAR BAND. THE ONE COMMENT I WOULD OFFER IS THAT SIX GIGA HERTZ HAS TO BE LOOKED AT CAREFULLY IN THE CONTEXT THAT WITHIN THE INDUSTRY WE REFER TO AS SORT OF THE TKPWOLDY LOCKS BAND BECAUSE WHILE THE HIGH BAND IS GREAT FOR URBAN CENTERS, THE LOW BAND IS GREAT FOR RURAL AREAS BECAUSE OF THE PROPAGATION CHARACTERISTICS BUT UNFORTUNATELY THE CAPACITY IS MUCH LOWER AND DOESN'T SUPPORT THE KIND OF LATENCY AND CAPACITY REQUIREMENTS I TALKED ABOUT IN MY COMMENTS. SIX GIGA HERTZ IS REALLY KEY TO IN SOME SENSE PROVIDING FOR ALL THE PROMISES ASSOCIATED WITH 5G AND IF YOU LOOK AT OTHER COUNTRIES AROUND THE WORLD. THEY TAKE AN ACTION ON SIX G, AND THE U.S. IS ACTUALLY BEHIND THE CURVE ON THAT ONE. AND SO, AGAIN, WE'RE CERTAINLY CONSISTENT WITH OPERATING AND NOT IN ANY WAY REPRESENTING A THREAT TO THE OPERATION OF INCUMBENTS IN THE SIX GIGA INHERIT BAND BUT IT IS SOMETHING WE NEED TO MOVE ON EXPEDITIOUSLY IN ORD FOR THE ROLE OUT OF 5G TO BE CERTAINTIED IN THE U.S.

I WANT TO SHIFT A BIT. YOU MENTIONED IN YOUR TESTIMONY, A NUMBER OF FOLKS MENTIONED THE SUPPLY CHAIN SECURITY AS INCREASED THREAT BASED ON JUST THE SHEER AMOUNT OF NEW EQUIPMENT THAT 5G BRING SPWOS PLAY BUT YOU SUGGESTED MY NOT BE AS BIG A DEAL AS SOME PEOPLE THINK BECAUSE THE U.S. TENDS TO GET EQUIPMENT FROM TRUSTED SUPPLIERS IN EUROPE AND SOUTH KOREA SO I WANT TO BETTER UNDERSTAND WHETHER 5G, IS INTRODUCING SUPPLY CHAIN RISKS THAT ARE MATERIALLY DIFFERENT FROM ANY OTHER KPAOUPBICATIONS EQUIPMENT OR IF YOU REALLY THINK THIS IS NOT--

SO THE INDUSTRY, MR. CHAIRMAN HAS A LONG TRADITION OF DEALING WITH THESE SORTS OF RISKS AND IN FACT MANY OF THE RISKS PARTICULARLY IN THE WIRELESS INDUSTRY THAT HAVE BEEN TALKED ABOUT THE IN PRESS FOR ALL PRACTICAL PURPOSES DON'T EXIST WITHIN THE WIRELESS INDUSTRY. WE WORK VERY CLOSELY WITH DHS, AND IN FACT, WE WORK WITH THE SUPPLY CHAIN TASK FORCE WITHIN THE DHS THAT'S ADDRESSING THIS ISSUE AND THIS IS ON BEHALF OF THE EXECUTIVE ORDER THAT THEY'RE WORKING UNDER TO ADDRESS THIS WHOLE QUESTION OF WHAT THE RISK ASSESSMENT IS, ACROSS THE ENTIRE TELECOM SECTOR AND WE'RE IN THE MIDST OF DOING THIS RIGHT AT THIS MOMENT. DO I THINK THAT THERE WILL BE NEW RISKS INTRODUCED WITH 5G, WELL THAT'S ALWAYS THE CASE WITH ANY NEW TECHNOLOGY, DO I THINK THE WIRELESS INDUSTRY HAS A TRACK RECORD OF NOT ONLY MAKING SECURITY A TOP PRIORITY BUT A TRACK RECORD OF MITIGATING ANY OF THOSE RISKS THE ANSWER IS ABSOLUTELY AND WE TAKE THAT VERY SERIOUSLY. RIGHT THERE IN TERMS OF BEING AT THE TOP OF THE LIST WITH RESILIENCIES AND RELIABILITY AND SECURITY AS ONE OF THOSE THINGS THAT IS INDEED WE TAKE VERY, VERY SERIOUSLY BUT AT THIS POINT IN TIME WE DON'T SEE ANY NEW RISKS THAT ARE INTRODUCED BY 5G. , A NUMBER OF YOU REITERATED THE IMPORTANCE OF UTILITIES AND TELECOM PROVIDERS WORKING TOGETHER TO PLAN FOR BLACK SKY DAYS AND COORDINATE RESPONSE, OBVIOUSLY BOTH THE ELECTRIC SYSTEM IS VERY COMPLEX FOR BOTH UTILITY ANDICLE COMOPERATORS, WHAT'S THE BEST WAY TO START THAT DIALOGUE AND UNDERSTAND THE INTERDEPENDENCIES FOR EXAMPLE, UNDERSTANDING HOW SEVERE WEATHER EVENT OR OTHER NATURAL DISASTER MIGHT IMPACT THE COMMUNICATIONS SYSTEM AND HOW THAT MIGHT IMPACT THE GRID OR VICE VERSA.

I THINK JUST TO SUM UP THOUGH ON THE 5G ISSUE WHICH IS A SIMILAR ISSUE, I THINK UPON FOR ELECTRIC UTILITIES WE WANT TO BE PART OF THE DISCUSSION ON THE CYBERSECURITYS RELATED TO DEPLOYMENT OF 5G AND THE ISSUES THAT MAY OR MAY NOT EXIST. FROM THE BEGINNING WE'RE STILL IN A ROLL OUT OF 5G, IT HAS *BT BEEN FULLY IMPLEMENTED YET SO IT WOULD BE BEST FOR US, I THINK UNDER THE UMBRELLA OF FEDERAL PROCESSES, TO BE INCLUDED IN THOSE DISCUSSIONS RIGHT NOW. BECAUSE I THINK, YOU KNOW SIMILAR TO MY COLLEAGUES SUPPORT OF US IN TERMS OF THIS INTERFERENCE ISSUE ON THE SIX GIGA HERTZ BAND WE WANT TO GO TO 5G, I THINK ALL AMERICANS DO BUT YOU ALWAYS WRITTEN THE RACE BY GOING FASTEST, YOU WIN BY HAVING THE BEST TEAM AND COLLABORATING AND I THINK WE NEED TO BE PART OF THAT COLLABORATION GOING FORWARD ON 5G, I THINK THAT SIMILARLY WITH COLLABORATION ON RESILIENCE AND RESPONSE, YOU KNOW THE ELECTRIC SECTOR HAS A LONG HISTORY OF WORKING TOGETHER PUBLIC POWER, CO OP, INVESTOR AND UTILITIES AFTER HURRICANE MICHAEL THERE WERE 30,000 PEOPLE DEPLOYED TO THE PANHANDLE OF FLORIDA TO RESTORE POWER AND THAT'S MANAGE SPH*ING THAT WE WOULD LOVE TO HAVE THAT KIND OF ON THE GROUND COLLABORATION WITH THE WIRELESS CARRIERS AND OTHER TELECOMMUNICATIONS PROVIDERS, I THINK THAT WOULD BE A GREAT PLACE TO START GROUND UP BUT FROM YOUR PERSPECTIVE AND THE FEDERAL GOVERNMENT, CONVENING CONFERENCES, EXCLUSIVELY FOCUSED ON THIS AND EVEN IF WE DID IT UNDER THE RUBRIC OF THE CP A C, SO IT'S UNDER KIND OF THE--SO WE DON'T HAVE TO REVEAL ALL OF OUR INFRASTRUCTURE ISSUES THAT MAY BE DETRIMENTAL IF FOLKS, NEFARIOUS FOLKS GOT AHOLD OF THEM, MAYBE WE DO IT THAT WAY CONVENE A JOYMENT MEETING, MAYBE HAVE JOINT OUTPUTS FROM SOMETHING LIKE THAT. BETTER UNDERSTANDING EACH OTHER'S INDUSTRY AND BUSINESS MODEL SYSTEM SOMETHING THAT'S VERY IMPORTANT AS WE GO FORWARD.

THEY THINK YOU FOR THAT, ONE FINAL QUESTION, MR. [INDISCERNIBLE] THANK YOU BOTH FOR YOUR PRESENTATION TODAY AND FOR SPENDING TIME WITH ME EARLIER TO WALK ME THROUGH THE 900 MEGAHERTZ BAND AND THE DIFFERENCES THAT WE'RE DEALING WITH HERE, I HAVE ONE QUESTION FOR POINT OF CONTRARYIFICATION HAVE YOU HEARD ANY CONCERN FROM UTILITYWHETHER THE CONCENTRATED OWNERSHIP OF THESE BANDS AND SPECTRUM COULD HAVE A NIGGATIVE IMPACT ON UTILITIES AND THEIR ADOPTION OF NEW TEGGIC--STRATEGICNOLOGYS.

PART PART OF FCC PROCEEDING THERE HAVE BEEN HAD SOME UTILITIES THAT EXPRESS CONCERNS THAT,'S PART OF THE PROCESS AND THEY HAVE A DETAILED WAY OF LOOKING INTO THOSE AND MAKING SURE THAT ANY INCUMBENT IN THAT 900 MEGAHERTZ BAND WOULD NOT BE HINDERED OR PREVENTED FROM BEING TILE DO WHAT THEY'RE DOING.

SO THE FCC HAS A PROCESS.

YES WE'RE ACTIVELY ENGAGED.

VERY HELPFUL THANK YOU. COMMISSIONER LAFLEUR NTHIS IS AN INTERESTING PANEL AND NOT MY AREA OF EXPERTISE SO I HOPE MY QUESTIONS ARE NOT UNINFORMED I HAD TO READ THE TESTIMONY TWICE TO UNDERSTAND WHAT I WAS RELATING. I DON'T KNOW HOW MANY WERE HERE THIS MORNING BUT I'M FINDING IT INTERESTING TO KIND UTV JUXTAPOSE THIS DISCUSSION WITH THE DISCUSSION WE HAD ON CLOUD COMPUTING AND VIRTUALIZATION BECAUSE THERE YOU'RE SAYING FERC YOU'RE HOLDING US BACK FROM THE FUTURE, WE DON'T WANT TO HAVE TO HAVE OUR OWN DEDICATED HARDWARE, WE WANT TO GO TO THE CLOUD, RELEASE US FROM THESE STUPID ROWELS THAT ARE KEEPING US FROM GETTING THE FULL BENEFITS FROM OUR KPUFT MERS OF ALL THESE NEW TECHNOLOGIES AND HERE IF FEELS LIKE ON SOME LEVEL, UTILITIES ARE SAYING WE WANT TO DO IT THE WAY WE ALWAYS DID IT WITH OUR FIXED POINT MICROWAVES THAT WE OWN AND WE DON'T WANT TO BE PART OF A WIRELESS NETWORK WITH ALL THE OTHER PEOPLE WHO ARE DOING WIRELESS AND IT'S--WE LIKE IT OUR WAY. AND I GUESS--FOR VERY CONVINCING REASONS, BUT IT JUST SEEMS LIKE THE MARCH OF TECHNOLOGY BEING SO FAST, MY QUESTION IS: DO YOU THINK 5G IS IN YOUR FUTURE AND CAN YOU SUPPORT IT ON YOUR SIX GIGA HERTZ AND THEN WHEN SIX G COMES ALONG OR SEVEN G, WHATEVER I'LL BE DEAD OR MAYBE, DEPENDING ON HOW LONG THIS HAPPENS, HOW LONG THIS TAKES, YOU'LL BE SAYING TPHORBGS, NO, NO, NO, OUR FIXED POINT MICROWAVE AND GOOD FOR US AND IT'S WORKED SINCE 1950 AND WE WANT IT NOW. DO YOU SEE YOURSELF MIGRATING? WHAT'S THE FUTURE HERE?

I'LL START. [LAUGHTER] SO THE QUESTION IS DOES THE FUTURE ENTAILILELY AVAILABLE ELECTRICITY. TECHNOLOGY IS BENEFITING UTILITIES IN MANY WAYS IN TERMS OF HOW WE HAVE BEEN ABLE TO CREATE A MORE FLEXIBLE GRIDOT POWER SYSTEM BUT ALSO ON THE DISTRIBUTION SYSTEM, SO WE'VE SEEN TECHNOLOGY MAKE GREAT STRIDES SO WE HAVEN'T BEEN DOING EVERYTHING THE SAME WAY SINCE 1950, IN FACT WE EMBRACED A LOT OF NEW TECHNOLOGIES BUT THE KEY ASPECT IS WE HAVE TO HAVE SAFE RELIABLE AND AFFORDABLE ELECTRICITY IN THIS COUNTRY AND IT UNDERPINS 5G. IT REALLY DOES, YOU CANNOT DO COMMUNICATIONS WIRELESS, COMMUNICATIONS WITHOUT ELECTRICITY, SO I THINK THE QUESTION IS HOW DO WE KIND OF MARRY THE TWO? HOW DO WE FIGURE OUT HOW TO CONTINUE TO PROVIDE HIGHLY RELIABLABLE STABLE ELECTRICITY WHILE UNLEASHING THESE TECHNOLOGIES. AND I THINK I WILL NOT REALLY TRY TO GET INTO SPEAKING ABOUT THE CLOUD TECHNOLOGY BUT I WILL SAY IT'S DIFFERENT, WHERE THE CLOUD FITTER VULLIZATION, AND BUT I DON'T WANT TO GET TOO FAR INTO THE WEEDS ON THAT AND NOD BE ABLE TO ANSWER THE QUESTION.

SO JUST A COUPLE COMMENTS ON THAT AS I'VE BEEN WORKING WITH UTILITIES AND TRY TO SELL THEM AT&T SERVICES AND THEY WANT TO MAINTAIN IT IN-HOUSE, NOTHING CLOUD, WHAT I SEE IS THE USE CASES, THE USE CASES HAVE CONTINUED TO GROW AND REQUIREMENTS FOR THOSE USE CASES ARE DIFFERENT BECAUSE IF IT'S CRITICAL INFRASTRUCTURE AND IT'S DATA RELATED AND SOMETHING THAT UTILITY DOES TO DO SAFE RELIABLE ELECTRICITY AND THEY WILL MAINTAIN CONTROL AND KEEP IT. IF IT BECOMES THE APPLICATIONS TODAY THAT THEY DELIVER TO SOME OF THEIR CONSUMERS THAT ARE LESS CRITICAL, THEY SEE THAT THE BEST WAY TO GET THEIR BEST RETURN ON INVESTMENT AND OPERATIONALLIZE IT IS TO MOVE IT TO THE CLOUD SO I'VE SEEN THAT WE'VE BEEN ABLE TO PROVIDE ADDITIONAL SERVICES, AND ACTUALLY I BELIEVE A COMBINATION OF BOTH IS WHAT I'M STARTING TO SEE, AND THAT IN SOME SITUATIONS, IT MAKES SENSE TO KEEP IT IN-HOUSE AND OTHER SITUATIONS THEY WANT TO MOVE TO A MORE COLLABORATIVE SITUATION.

SO DO YOU THINK YOU WILL GET TO THE PLACE WHERE UTILITIES AREUING THEIR MICROWAVE SYSTEM FOR CONTROLLING THEIR POWER PLANTS OR TRANSMISSION GRID BUT ALL THEIR COMMUNICATING WITH CUSTOMERS LIKE TURN YOUR CAR BATTERY ON AND OFF, MILLIONS OF CUSTOMERS WILL BE WIRELESS?

I THINK THAT'S THE--

I KNOW IT'S ALL WIRELESS WHAT WILL BE A DIFFERENT KIND OF WIRELESS.

NOT ALL WIRELESS, BUT YES, I THINK THAT'S RIGHT.

THE SPECTRUM--

YES, THE SPECTRUM.

YES.

I WANT TO BE CAREFUL TOO, TO MY COMMENTS, I WANTED TO SHOW YOU AND ILLUSTRATE, THE IMPORTANCE OF SOME OF THESE COMMUNICATIONS AND HOW THEY'RE UNIQUE, I THINK IN THAT YOU KNOW THEY'RE BEING USED TO CONTROL THE BULK ELECTRIC SYSTEM AND THAT'S A CRITICAL THING FROM OUR PERSPECTIVE. WE'RE NOT NECESSARILY THOUGH TRYING TO SAY THAT YOU KNOW THIS HAS TO BE OUR WAY AND WE DON'T ACCEPT ANY OTHER WAY. IT REALLY--THE MESSAGE AT END WAS INTENDED TO BE A COLLABORATION MESSAGE AND LET'S JUST MAKE SURE THAT IF WE'RE GOING TO DO THIS THAT IT'S DONE WELL, IT'S DONE RIGHT AND THAT WE WORK TOGETHER AND I THINK PROBABLY TALKING TOGETHER WILL BE THE BIGGEST THING THAT COMMUNICATIONS WILL BE IMPORTANT AND STRESSING THAT I THINK YOU KNOW PERHAPS FERC AND FCC COMMUNICATION WILL BE GOOD TO BE SURE THESE ARE BEING DONE AND PRESERVE THE RELIABILITY SECURITY COST OF ELECTRIC SYSTEM. SO WANT TO POINT THAT OUT.

THANK YOU. I'M GLAD YOU MENTIONED THE COST EFFECTIVENESS BECAUSE I GUESS MY QUESTION IS LET'S SAORBGS SOUP THE FCC STAYS ON THE PATH THEY'RE ON AND FERC THEY MEET WITH US, I'M SURE THEY WILL MEET WITH US IF WE ASK TO, THEY'RE VERY NICE PEOPLE BUT I MEAN THEY'RE PURSUING THEIR POLICY AND AND THEY KEEP ON IT, WHAT WILL YOU DO? WILL YOU KEEP USING THE SIX GIGA HERTZ AND SHARE IT, WILL YOU GO BY LOAD FREQUENCY SPECTRUM FOR MIKE? WILL YOU TRY THE HIGHER FREQUENCY 5G AND LIKE, I KNOW YOU HAD TO GO FROM THE TWO TO THE SIX ALREADY YOU SAID BUT WILL YOU BE ABLE TO GET IT BUT IT WILL COST MORE MONEY OR--OR WHAT?

CAN I ADDRESS THAT? SO THE PROPOSAL BEFORE THE FCC,S PROPOSAL THAT THE FCC HAS TO PUT ON IN THE NOTICE OF PROPOSED OF RULE MAKING LAST FALL IS TO ALLOW UNLICENSED USE OF 1.2 GIGA HERTZ OF SPECTRUM WHICH IS A WIDE SWATH OF SPECTRUM. WHILE ALLOWING CONTINUED USE FOR FIXED SERVICES BY ALL THE INCUMBENTS. IF THEY WANT TO PUT UP A NEW LINK, GREAT, UNLICENSED WILL HAVE TO PROTECT THAT LINK. SO IN QUALCOMM'S VIEW, IT'S A VERY GOOD METHOD OF SHARING WHERE THE LICENSE THE USERS CAN CONTINUE TO DEPLOY AND GROW IF THEY NEED TO PUT A LINK FROM A-B THAT ISN'T THERE OR REMOVE ONE AND UNLICENSED WILL OPERATE IN THE INTER[INDISCERNIBLE] IF YOU WILL TO NOT CAUSE INTERFERENCE. THERE ARE SOME ENTITIES AT THE FCC INCLUDING CTIA AND MEMBER COMPANIES HAVE IDENTIFIED A PLAN TO SEGMENT THE BAND. DO UNLICENSED LIKE I JUST LAID OUT IN THE LOWER PORTION OF THE BAND AND IN THE UPPER PART OF THE BAND, HAVE THE PROCESS FOR MOVING THE INCUMBENT USERS OUT OF THE BAND AND I DON'T--I DON'T BELIEVE THAT'S SOMETHING THAT THE UTILITIES ARE GOING TO BE SUPERINFAVOR OF.

WHERE WOULD THEY MOVE TO? A DIFFERENT BAND?

THAT'S PART OF THE ISSUE BUT PART OFA IS A SLIGHTLY HIGHER BAND SO THERE'S A LOT IN THE MIX BUT WHAT'S IN THE FCC'S PROPOSAL IS CONTINUED LICENSED FIXED SERVICE USE IN THE FULL 1.2 GIGA HERTZ AND TO HAVE UNLICENSED OPERATE IN A MODE WHERE IT MUST PROTECT THE LICENSURE.

BUT IF THE UTILITY NEED FOR THE SPECTRUM JUST GROWS AND GROWS AS THEY HAVE INSTEAD OF JUST THESE BIG POWER PLANTS NOW THEY HAVE LITTLE DISTRIBUTED AND ALL, WILL THEY JUST KICK OUT MORE OF THE UNLICENSED?

YES, YES THAT'S WHAT EXACTLY WHAT WILL HAPPEN. IF IT GROWS AND GROWS AND GROWS BECAUSE UNLICENSED HAS NO LEGAL RIGHT. THE FCC'S RULES FOR UNLICENSED IS AN UNLICENSED DEVICE MUST ACCEPT ALL INTERFERENCE AND IT HAS NO INTERFERENCE RIGHTS ITSELF. SO THEREFORE IF WHAT YOU'RE LAYING OUT IS THE UNIVERSE OF LICENSED USE GROWS TREMENDOUSLY AND THERE ARE THESE LINKS, THE AVAILABLE SPECTRUM FOR UNLICENSED MUST NECESSARILY TREND.

SO HERA THE THING WHEN THESE ARE MAPPING FOR THESE CRITICAL COMMUNICATIONS, JUST THIS THREAT OF *EURPT FER ENSEL? IF WE DON'T GET THIS INTERFERENCE PIECE RIGHT? THE THREAT OF INTERFERENCE FROM ALL OF THOSE UNLICENSED IT COULD BE 9 MILLION OF THEM, MILLIONS OF UNLICENSED USERS COULD BE IN THIS BAND AND THEY'RE SUPPOSED TO ABIDE BY, YOU KNOW CERTAIN RULES WHEN THEY PURCHASE THEIR DEVICE, YOU KNOW BUT ARE THEY GOING TO? ARE THEY GOING TO ABIDE BOY THOSE RULES, NOT NECESSARILY, SO WHY WON'T KNOW WHERE THEY ARE, HAY WE WON'T KNOW IF INTERFERENCE WILL HAPPEN UNTIL IT DOES. SO THAT RISK AND I KNOW THAT THIS IS THAT HIGH IMPACT LOW FREQUENCY RISK THAT WE ALWAYS DEAL WITH HERE, EMPS, GMD, ALL THE THINGS THAT FERC IS FAMILIAR WITH, WE'RE EXPECTED TO ADDRESS THOSE HIGH IMPACT LOW FREE RADICALSIENCY RISKS ALL THE TIME, RIGHT IN AND SHOULD PROBABLY A LITTLE BIT HIGHER FREQUENCY RISK MAN NOT TO--NONAPOPTOTIC TO MIX METAPHORS.

HOPEFULLY WE WILL SEE INTERFERENCE MORE THAN A [INDISCERNIBLE] SOUTH AMERICA YEAH BUT IN A SENSE THAT WE'RE EXPECTED TO HAVE HIGHLY RELIABLE COMMUNICATIONS ON OUR POWER SYSTEM SO WE CAN HAVE SITUATIONAL AWARENESS APPROXIMATE. THE IDEA, IDEA OF INTERFERENCE IS GOING TO HAVE UTILITY VS TO CALL INTO QUESTION USING THIS BAND AT ALL.

WILL THEY USE A DIFFERENT BAND?

YES THERE IS NOT--

WE CAN'T GO BACK TO WIRE LINE FOR EVERYTHING.

CORRECT. AND THAT'S THE QUESTION, WE DON'T KNOW THAT THERE ARE. THERE ARE SOME BANDS IN MUCH HIGHER USAGE THAT ARE LIKE 11 GIGA LETTERS AND HIRER THAT ARE IDENTIFIES BUT IT WOULD TAKE A LONG TIME TO BUILD THOSE OUT. THERE'S A CHALLENGE OF LENGTH OF TIME TO WORK THAT OUT FOR US? THOSE ASSESSMENTS HAVEN'T BEEN FULLY MADE BECAUSE WHEN THIS PROCESS WAS INITTIAITED WE WERE NOT CONSULTED AT THE BEGINNING SO WE HAVEN'T BEEN PLANNING FOR AND IDENTIFYING AND DISCUSSING THOSE OTHER RELATIONSHIP REAVESA THE THIS POINT SO IF THE SKRERBGS C PROCEEDS THE KEY THING WILL BE GETTING THIS *EURPT FERNESS MITIGATION RIGHT AND TESTING IT FULLY. IN THE FIELD.

HOW ABOUT THE 900-HERTZ BAND IS THAT OF INTEREST OR--

IT'S NOT A PLACE WE REQUEST GO TO THE DO THE SAME THING WHAT'SY CAN DO, IT'S DIFFERENT AND IT CAN BE HELPFUL FOR SOME AND IT IS - ALREADY USED BY CRITICAL INFROM STRUCTURE BUT IT'S NOT THE SAME TYPE OF NEED.

I DON'T KNOW IF I WILL BE HERE WHEN IT HAPPENS BUT IF THERE'S A MEETING WITH THE FCC IT WOULD BE IMPORTANT TO BE SPECIFIC ABOUT WHAT IT IS WE WANT BECAUSE I'VE JUST HAD A LOT OF INTERGOVERNMENT MEETINGS SINCE I'VE BEEN IN GOVERNMENT WHERE THERE'S JUST KIND OF A GENERAL DISCUSSION OF THE NEEDS OF BOTH PIECES OF INFRASTRUCTURE AND THEN IT DOESN'T ACTUALLY AFFECT AFTER THE MEETING WHAT THE PEOPLE WHO WERE REALLY WORKING ON WHAT THEY'RE AN EXPERT ON ARE WORKING ON SO IT WOULD BE MORE IF IT'S MORE TESTING, IF IT'S A CERTAIN TIMELINE OR WHATEVER IT IS WE WANT TO WHAT COMMISSIONER GLICK WAS SAYING, WE WOULD HAVE TO BE VERY SPECIFIC. BECAUSE THAT'S JUST GOING IN AND SAYING ELECTRICITY IS REALLY IMPORTANT AND WHAT ABOUT THIS. THOSE ARE THE KIND WE NORMAL HAVE AND THEY--THEY'RE GOOD FOR BUILDING AWARENESS OF EACH OTHER BUT YOU'RE ASKING FOR SOME BRETTY SPECIFIC NEEDS SO I THINK THE MORE--PRETTY SPECIFIC NEEDS SO MORE CLARITY OF WHAT WE HAVE THE MORE EFFECTIVE IT WILL BE. THANK YOU.

? I WANT TO CONTINUE DOWN THE PATH THAT COMMISSIONER LAFLEUR HAD, IT STRIKES ME HERE THAT WE USE THE TERM INTERFERENCE AND I'M NOT SURE WHAT INTERFERENCE MEANS, YOU GO BACK AND HAVE A LAWYER CALLING HIS HIGH SCHOOL PHYSICS IDEA BUT THE WAY YOU CAN HAVE INTERFERENCE FROM SOMETHING CROSSING THROUGH ANOTHER WAVE OR IN THE SPECTRUM HAVE YOU TOO MUCH USAGE IN THERE AND IT SOUNDS LIKE WE'RE HERE ON THE ONE END THAT THE ENERGY AND INDUSTRY, ELECTRIC INDUSTRY WILL BE INCREASING THE USE OF THE SPECTRUM, YOU HAVE THE DESIRE FOR TELECOMS TO GET INTO THAT SPECTRUM, THEY WILL WANT TO BE USING IT SO IT'S LIKE INTERFERENCE WILL JUST BE--AT SOME POINT THERE MIGHT BE TOO MUCH IN THERE. THAT'S PART OF A QUESTION, THE OTHER PART IT IF YOU HAVEN'T USED THE SPACE BUT THINGS ARE CROSSING?

THE ISSUE WITH INTERFERENCE IS TYPICALLY PROTECTING THE RECEIVER, SO IF I'M TRANSMATING FROM HERE TO HERE AND I HAVE A CERTAIN POWER LEVEL. THE POWER LEVEL AT THE RECEIVER WILL BE QUITE HIGH BUT IF I AM FIXED KILOMETERS AWAY, THAT SIGNAL THAT I'M TRYING TO TRANSMIT FROM HERE TO HERE AND THAT RECEIVER IS NOW 6-KILOMETERS AWAY, YOU KNOW THE SIGNAL LEVEL, AT THAT RECEIVER IS A LOT LOWER. SO THE ISSUE IS PROTECTING THAT RECEIVER FROM UNWANTED NOISE, THAT IS SUCH A LEVEL THAT IT DISRUPTING IT. SO THE FCC DEFINITION OF HARMFUL INTERFERENCE IS INTERFERENCE THAT DISRUPTS OR DEGRADES A SERVICE REPEATEDLY. IT'S IN THE FCC'S RULES WHAT HARMFUL INTERFERENCE--

REPEATEDLY OR AT ALL? NIBELIEVE IT'S REPEATEDLY. I CAN PROVIDE TO YOU AFTER THE--

YEAH, I MEAN CAUSES DEGRADATION IN THE SERVICE. SO IF THERE'S *EURPT FER ENSEL IF IT'S A BLIP, LET'S SAY IT'S A BLIP, NOISE, CLOUD GOES BY, DRONE FLIES, AIRPLANE TAKES OFF, AND IT'S INSTANTANEOUS IT'S NOT HARMFUL INTERFERENCE, BUT IF THERE'S A SIGNAL PREVENTING RECEPTION, THAT IS HARMFUL INTERFERENCE AND THAT'S A PROBLEM. AND DETERMINING THE IMPACT IS SO YOU DON'T JUST DOJ AN ALGATE KEEPER PRAYICIICATION, THERE'S MODELING INVOLVING DISTANCE, DIRECTIVITY, THE ANTENNA GAIN, THE THE SOURCE OF THE UNWANTED NOISE. THIS IS SOMETHING THAT THE FCC IS AN EXPERT IN AND THEY'RE FULLY AWARE AND EVERY SYSTEM IS DIFFERENT. THERE ARE SYSTEMS FOR EXAMPLE, YOU MAY HAVE HEARD SEVERAL YEARS AGO THERE WAS ISSUE WIDE A NEW SERVICE IMPACT IN GPS, WELL THE RECEIVER FOR GPS IS RECEIVING SIGNALS AT SUCH A LOW LEVEL THAT EVEN OUT OF BAND NOISE IN THE DIFFERENT CHANNEL WAS CAUSING PROBLEMS WITH THE RECEPTION OF GPS SIGNAL TAKEN--THEY WAS USED FOR PRECISION AG GRID SERVICES CULTURE FOR EXAMPLE, AND THAT WAS AN ISSUE, BUT IF BECAUSE THE SIGNAL LEVELS WERE AT SUCH A LOW LEVEL, THAT AN OUT OF BAND SIGNAL WAS CAUSING PROBLEMS TO THAT. SO, YOU KNOW IT'S KIND OF--THERE'S NO SET ANSWER AND IT'S BASICALLY A CASE BY CASE ANALYSIS. AND IN THIS CASE, IN THE SIX GIGA HERTZ BAND IT IS PROTECTING THE FIXED RECEIVER AND THEY ARE A POINT TO POINT TRANSMISSION LINK, KIND OF LIKE--THEY'RE VERY DIRECTIVE SO IF I'M TRANSMITTING WITH YOU AND MY RECEIVER GETTING TILTED BY THIS, YOU WILL NONAPOPTOTIC THE RECEIVE MY SIGNAL SO I HOPE I ANSWERED YOUR QUESTION.

IT'S HELPFUL.

IF I MAY INTERJECT, ONE THING I THINK WE SHOULD BEAR IN MIND IS THAT *EURBT FER ENSEL IS NOTHING NEW TO THE WIRELESS INDUSTRY. IT'S SOMETHING THAT THE WIRELESS INDUSTRY AND THE FCC HAS AN UNUSUALLY GOOD TRACK RECORD OF INSURING THAT THE RULES ARE FOLLOWED AND THAT INDEED WE KNOW HOW TO DEAL WITH THE KINDS OF SCENARIOS THAT JOHN JUST TRIBED. AND THE ISSUE IS THAT I THINK WE NEED TO TAKE THAT INTO,A COUNT. I MEAN I THINK WE NEED TO TAKE INTO ACCOUNT THAT THERE'S ENGINEERING THAT GOES BEHIND THIS. TYPICALLY WHEN THESE SORTS OF ISSUES GETS RESOLVED AND THEY HAVE BEEN RESOLVED IN THE PAST IN OTHER BANDS IS YOU GET THE SUBJECT MATTER EXPERTS TOGETHER, THE RF ENGINEERS TOGETHER IN A ROOM AND THEY WILL GO THROUGH THE CALCULATIONS TO ASCERTAIN WHEN THERE'S A RISK FOR INTERFERENCE OR NOT, BUT AGAIN I THINK FROM WHAT YOU'RE SEEING, THERE'S A COMMITMENT ON THE PART OF THE INDUSTRY TO SUPPORT THAT COLLABORATION, WE WELCOME IT, IT'S BEEN DONE BEFORE AND THERE'S A PROVEN TRACK RECORD AT THE FCC OF HOW THIS IS GONE SO I THINK WE NEED TO LEVERAGE THAT BECAUSE WHILE SIX GIGA HERTZ IS CERTAINLY A BAND, A VERY IMPORTANT BAND, THERE ARE PLENTY OF EXAMPLES HOW THESE SORTS OF ISSUES THAT BEEN DONE BEFORE AND HOW WE PROTECTED INCUMBENTS OR THEY'VE BEEN REMOVED OR REMAINED IN THE BAND BUT THERE'S SUFFICIENT PROTECTION SO THEY'RE NOT INTERFERED WITH AND WE CAN'T LOSE SITE OF IT BECAUSE IF WE DO WE RUN THE RISK THAT AGAIN WE COULD BE TALKING ABOUT THIS AGAIN IN 24-36 MONTHS WITHOUT HAVING DONE ANYTHING ABOUT SIX GIGA HERTZ.

SO IT COMES BACK TO THE QUESTION OF WHAT I HEARD FROM SOME OF THE OTHER PANELISTS BEFORE WAS THAT THEY WANTED TO INSURE THE INCUMBENTS IN THE BAND ARE PROTECT FRIDAY INTERFERENCE AND I HEARD THAT EARLIER. THE ISSUE IS WHILE THE EXPERIENCE OF JOHN MAY HAVE BEEN THAT THE FCC HAS A PROVENY TRACK RECORD THERE HAVE BEEN MISTAKES YOU HEARD ABOUT ONE WITH GPS, IT'S NOT ALWAYS TOTALLY SCIENTIFIC. AS YOU HEARD CASE BY CASE ISSUES. THE REASON THERE ARE LICENSED SPECTRUM BAND IS PRECISELY BECAUSE OF INTERFERENCE, BECAUSE THOSE LICENSED USERS NEED BIGGER GUARANTEES ABOUT INTERFERENCE MITIGATION. SO THEREFORE THERE ARE LICENSED BANDS TO ACCOMMODATE THEM, INTRODUCING UNLICENSED MEANS THEY DON'T HAVE CONTROL OR VISIBILITY INTO THAT UNLICENSED USE, SO THEY CAN'T--YOU KNOW UNLESS THERE ARE STRINGENT MITIGATION MEASURES THAT WE BELIEVE ARE UNTESTED AND PROVEN TO DATE THAT WE HOPEFULLY WILL BE TESTED AND PROVEN SO THAT THEY CAN BE MITIGATED AGAINST, YOU WOULD NOT BE CONFIDENT IN THE ELECTRIC SECTOR THAT THAT INTERFERENCE WILL BE MITIGATED THOROUGHLY ENOUGH TO INSURE ELECTRICAL LIABILITY. AND IF THE GOAL IS TO PROTECT INCUMBENTS FROM INTERFERENCE THAT WAS AGREED TO BEFORE, IT SHOULD TAKE WHAT IT TAKES TO GET TO THAT POINT WHERE WE HAVE THE CONFIDENCE THAT WE CAN USE THE BAND FOR ELECTRIC RELIABILITY. THAT'S A FUNDAMENTAL ISSUE HERE SO WE'RE HAPPY AND LOOK FORWARD TO THE COLLABORATION BUT WEB CONNECTED HAVE TO KEEP OUR EYE ON THE BALL. THERE'S REASONS WHY THERE'S TWO TYPES OF SPECTRUMS ISSUES LICENSE AND UNLICENSED THAT WE'RE ALREADY--SO THERE'S RECOGNITION THAT IT'S A POSSIBILITY.

ON THE GPS ISSUE JUST TO BE CLEAR, THE INTERFERENCE I DESCRIBED WAS DUE TO TESTING OF A PROPOSED SERVICE HAD, THAT WAS NOT THE QUOTE.

I'M CONCERNED THAT WE HEARD IN PANELS EARLIER TODAY IN THE THEME DISCUSSION ABOUT SAFE COMMUNICATION AND HAVING THE SAME TERMS. I'M A LITTLE WORRIED FROM THE CONVERSATION I'M HEARING ABOUT WHAT RELIABLE SERVICE IS THAT IN THE TELECOM AND I'M NOT A TELECHOP EXPERT BUT FROM WHAT YOU'RE SAYING IF YOU HAVE A FEW BLIPS THAT'S RELIABLE SERVICE.

IF IT CAN WITHSTAND IT.

YOU KNOW YOU'RE ON YOUR CELL PHONE IT'S NOT A BIG DEAL WITH IT CUTS OUT. OT ELECTRIC SIDE, YOU HAVE A BLIP IT MAY DISRUPT A DISPATCH SIGNAL THAT'S CRITICAL SO THAT ONE MISTAKE COULD BE A VERY BIG PROBLEM THAT ISN'T--YOU CAN BE THE TOLERATE. I'M NOT SAYING THAT'S WHAT IT IS BUT IT SEEMS TO ME THERE MAY BE A FUNDAMENTAL PROBLEM THAT FCC'S SPEAK ABOUT WHAT IS TOLERABLE AND FERC SPEAK ABOUT WHAT'S TOLERABLE ARE TWO DIFFERENT STANDARDS AND WE'RE NOT SAYING THE SAME THING AND SO WE'RE NOT ABLE TO GET A PROPER RESOLUTION TO IT SO I WOULD URGE THAT YOU ALL MAKE SURE THAT YOUR UNDERSTANDING THE SAME THING SO YOU DON'T SAY OH WE'RE RELIABLEOT TELECOM SIDE, YOU CAN TOLERATE THE BLITZ FOR WHATEVER COMPLETELY AGREE, SO IF THERE IS A LINK THAT IS ENGINEERED TO 59S OR 69S RELIABILITY, THAT RELIABILITY MUST BE MAINTAINED? MUST BE MAINTAINED.

LET ME ADD ABOUT AND I'M THE LAST PERSON TO TALK ABOUT INTERFERENCE BUT THAT'S SHARED EXPECTATIONS AROUND INTERFERENCE, WHAT THAT LOOKS LIKE, WHAT'S ACCEPTABLE AND NOT, BETWEEN FER, FCC, DIFFERENT UTILITIES AND DIFFERENT ORGANIZATIONS TPHAOEUGZATIONS WHAT'S ACCEPTABLE AND NOT AND HAVING THOSE SHARED EXPECTATIONS TO ME, THAT WOULD BE A KEY THING.

I THINK THAT'S WHY I HAVING THIS TODAY IS SO IMPORTANT BECAUSE THIS CONVERSATION IS IMPORTANT AND I'M GLAD TO SEE THE REPRESENTATIVE FOR THE FCC HERE AND THESE ARE--THESE ARE THE KIND OF DISCUSSIONS WE NEED TO HAVE TO FLESH THESE OUT.

WE HAVE BEG YOUR PARDON 15 MINUTES LEFT UNLESS MY COLLEAGUE VS ANY FURTHER COMMENTS, QUESTIONS, CLOSING STATEMENTS, WE WILL TURN IT OVER TO STAFF FOR QUESTIONS?

WE JUST WANT TO THANK THE PANELISTS FOR ATTENDING TODAY, FANTASTIC JOB. WE HAVE NO REQUESTIES FROM THIS SIDE. [LAUGHTER]

I'LL THROW ONE BRIEF QUESTION OUT. I KNOW THERE WAS A LOT DISCUSSED IN HERE ABOUT SMART METERS ACCIDENT DISTRIBUTION NETWORKS COMMUNICATIONS FROM THE DISTRIBUTION SITE, HAVE Y'ALL BEEN ENGAGING NARUK AND STATES AS FAR AS THIS DISCUSSION AS WELL.

YES.

YES WE HAVE.

YES.

YES.

[LAUGHTER]

WITH THAT, THIS CONCLUDES OUR TECHNICAL CONFERENCE. I WANT THANK ALL THE PANELISTS THROUGHOUT THE DAY FOR THEIR PARTICIPATION, TESTIMONY AND CANDID DISCUSSION AND I PARTICULARLY WANT TO THANK ALL OF THE COMMISSION STAFF THAT PUT A TREMENDOUS AMOUNT OF TIME, EFFORT AND ENERGY INTO THIS. I THINK TODAY WAS A VERY PRODUCTIVE DAY AND IS OWED SOLELY TO YOUR EFFORT, SO THANK YOU. [MUSIC ]