​​The FERC staff white paper was issued on June 18 and proposed frameworks where FERC-jurisdictional utilities could seek transmission rate incentives for certain cybersecurity investments that are over and above what is required in the NERC cybersecurity standards.  NRECA’s comments filed on Aug. 17 focused on ensuring the following: there are benefits for non-jurisdictional utilities; incentives are carefully considered before being granted; and that key criteria must be met in order to qualify for incentives.