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Is DCS in or Out of NERC CIP?

I’m on my way to do an assessment and recommendations for a large gas/stream power plant on the east coast. As we all know NERC CIP has never mentioned the DCS and we have all assumed it only includes the EMS/SCADA. I personally think with the newer DCS that are no longer a closed system but have firewalls instead OPC or RIG any that we must include the NERC in our complaince and more important in reporting in CIP v5. I would like to hear what like minded people with a generation background think? ted@NERCCIPv5.org