On July 1 NRECA filed comments with FERC on their “Virtualization and Cloud Computing Services” Notice of Inquiry (NOI).  FERC’s NOI asked numerous questions regarding benefits, disadvantages, risks and costs of virtualization and cloud computing services used in bulk electric system operations and NERC cybersecurity standard compliance programs. NRECA used direct feedback from our members to explain in our comments how/why co-ops are and aren’t using these technologies, and stressed that if the NERC cybersecurity standards are revised to explicitly permit the use of these technologies, FERC must ensure that flexibility continues to exist for those co-ops that are using non-virtualized, non-cloud technologies for operations or compliance purposes.
 
NRECA noted that some co-ops are successfully using virtualization technology today to isolate operating systems and limit potential attacks while using proven methods for overcoming potential risks. However, the technology costs and complexity could make those systems impractical for smaller co-ops.  Additionally, NRECA explained that the potential benefits for using cloud computing services for grid operations are currently more limited and the risks are substantial. Electric co-ops generally do not believe it is currently in their best interest to use cloud-based services for critical, real-time grid control operations.