What is a Technical Feasibility Exception?
With the issuance of Order No. 706, FERC noted generally that there is legacy equipment on the bulk power system that may not meet the CIP requirements on day one, and although equipment replacement will often be appropriate to comply with the CIP standards, such as in instances where equipment is near the end of its useful life, the possibility of being required to replace equipment before the end of its useful life is a valid concern. As a result, FERC proposed to allow, in the near term, exceptions from compliance based on the concept of “technical feasibility” (referred to as Technical Feasibility Exceptions, or TFEs) in a limited set of circumstances. FERC observed that exceptions may be recognized, not only for technical feasibility reasons, but also for operational and safety considerations.
