Rulemaking Comment of GE Power Systems, Energy Consulting re Critical Energy Infrastructure Information under RM02-4.

g GE International, Inc. Comments on the Proposed Procedures for Handling Critical Energy Infrastructure Information Docket No. RM02-4-000 Introduction GE Power Systems Energy Consulting (PSEC) respectfully submits these comments in response to the Federal Energy Regulatory Commission Notice of Proposed Rulemaking issued September 5, 2002 under docket RM02-4-000. PSEC has a long history of providing technical consulting services to the electric power industry, traceable back to at least the 1920s. During this time, PSEC was responsible for development of many of the techniques and tools employed in performing technical analyses of electric generation and transmission systems Because PSEC is part of a private industrial corporation that serves the industry at large, our tradition has been to refrain from involvement in public debates on regulatory matters. Instead, we have focused our efforts entirely on generic technical investigations with results published through the auspices of technical bodies such as IEEE and CIGRE, and on addressing project-specific issues for the clients we serve on a commercial basis. The events of September 11, 2001 were profoundly disturbing to us, and as system planners and analysts, we immediately recognized that the electric power system in the US could also be another target for terrorists intent on destroying our economy and society. In the intervening months, we have given a lot of thought to the implications of that risk. At the same time, we have experienced a direct impact on our ability to support the clients we serve; we were among the 138 entities who applied for access to information under the Freedom of Information Act and whose applications were denied. POWER SYSTEMS ENERGY CONSULTING LJP8506.doc - Rev (0)Confidential Information printed page # of 1 pages created 03 October 2002 g GE International, Inc. The Impact of Grid Data on National Security Data collected by the Department of Energy (DoE) for the period of 1984-1999 and analyzed by NERCs Disturbance Analysis Working Group (DAWG) identifies a number of attempts to sabotage the electric grid in North America. Fortunately, all of these attempts were unsuccessful. There are two reasons for this uniform lack of success. First, because the electric grid is exposed to a wide variety of threats, the most significant of which historically has been uncontrollable atmospheric conditions, it must necessarily be designed to be resilient and largely self-healing. The traditional design criterion is n-1. That is, the transmission grid is designed withstand failure of any component with no impact ...