​​​​The American Public Power Association (“APPA”), Edison Electric Institute (“EEI”), Electricity Consumers Resource Council (“ELCON”), Electric Power Supply Association (“EPSA”), Large Public Power Council (“LPPC”), National Rural Electric Cooperative Association (“NRECA”) and Transmission Access Policy Study Group (“TAPS”) (together, the “Trade Associations”), on behalf of their members, hereby respond to the Notice of Petition for Rulemaking (“Notice”) issued by the Federal Energy Regulatory Commission (“the Commission” or “FERC”) soliciting comments on the Foundation for Resilient Societies’ January 13, 2017 Petition for Rulemaking.1 The Petition asks the Commission to initiate a rulemaking to require the development of an enhanced reliability standard to detect, report, mitigate, and remove malware from the Bulk Power System (“BPS”). FULL FILING