On October 28, 2019 ​NRECA joined with APPA, EEI, EPSA, ELCON, TAPS and LPPC to file comments with FERC on a FERC/NERC staff white paper that proposes to make public the names of utilities that violate NERC cybersecurity standards.  The comments address the concerns we all have with making public the names of violators, especially if other related information is also made public.  We don't believe FERC/NERC staff have made a compelling case to change the policy of keeping the names confidential.  If the decision to make the names public goes forward, the comments explain why certain other related information should not also be made public.  The primary reason for the FERC/NERC white paper proposal is to attempt to balance public transparency and security of the grid in response to FOIA requests that FERC received for the utility name information.