Technical Feasibility Exception (TFE)

A responsible entity may request an exception from Strict Compliance with the terms of a requirement of certain NERC Critical Infrastructure Protection (CIP) Standards on the grounds of technical feasibility or technical limitations. Such an exception is a Technical Feasibility Exception (TFE). TFEs are applicable only to those requirements of CIP Standards CIP-002 through CIP-014 that expressly provide one of the following conditions:

  • Compliance with the terms of the requirement is required where or as technically feasible, or
  • Technical limitations may preclude compliance with the terms of the requirement.

Please refer to the NERC Rules of Procedure, Appendix 4D, “Procedure for Requesting and Receiving Technical Feasibility Exceptions to NERC Critical Infrastructure Protection Standards” for more details. 

A registered entity may use one TFE Request Form to request a TFE for the same applicable requirement for multiple, similar Covered Assets (either at the same location or at different locations within the geographic boundaries of a Regional Entity) on the same basis, with the same compensating measures and/or mitigating measures, and with the same proposed expiration date. The TFE Request Form, including the Covered Cyber Assets template used to document the list of covered assets, is available in the Compliance Portal.  You can also download the Covered Cyber Assets template and upload it into the Compliance Portal TFE Request Form. 

Within 60 days after receipt of the TFE Request or Material Change Report, SERC will complete its review and determine to approve or disapprove. In addition, the SERC may extend the 60-day time period for individual TFE Requests or Material Change Reports by issuing a notice to the registered entity.