CISA Issues Updated Essential Services Guidance, March 28

Over the weekend, the federal Cybersecurity and Infrastructure Security Agency issued an updated “Coronavirus Guidance for America” memo to further clarify essential critical infrastructure workers during COVID-19. The guidance specifically identifies renewable energy workers as essential. This update provides further evidence in support of CALSSA’s guidance published March 21 encompassing all forms of solar energy and energy storage.

“Workers supporting the energy sector through renewable energy infrastructure (including, but not limited to wind, solar, biomass, hydrogen, ocean, geothermal, and/or hydroelectric), including those supporting construction, manufacturing, transportation, permitting, operation/maintenance, monitoring, and logistics. “ (page 7)

Manufacturing and distribution of equipment, supplies, and parts necessary to maintain production, maintenance, restoration, and service at energy sector facilities (across all energy sector segments). (page 7)

“Workers at renewable energy infrastructure (including, but not limited to wind, solar, biomass, hydrogen, geothermal, and/or hydroelectric), including those supporting construction, manufacturing, transportation, permitting, operation/maintenance, monitoring, and logistics.” (page 8)

IMPORTANT NOTE:

In issuing this memo, CISA makes note that federal guidances are just that: guidances. All businesses must adhere to state and local authorities. And all essential services must adhere to government issued guidances on strategies to limit disease spread and focus only on core business activities including delaying in-person and non-mandatory activities. CISA offers the following guidances:

1. Response efforts to the COVID-19 pandemic are locally executed, state managed, and federally supported. 

2. Everyone should follow guidance from the CDC, as well as State and local government officials, regarding strategies to limit disease spread. 

3. Workers should be encouraged to work remotely when possible and focus on core business activities. In- person, non-mandatory activities should be delayed until the resumption of normal operations. 

4. When continuous remote work is not possible, businesses should enlist strategies to reduce the likelihood of spreading the disease. This includes, but is not necessarily limited to, separating staff by off-setting shift hours or days and/or social distancing. These steps can preserve the workforce and allow operations to continue. 

5. All organizations should implement their business continuity and pandemic plans or put plans in place if they do not exist. Delaying implementation is not advised and puts at risk the viability of the business and the health and safety of the employees. 

6. Reliance on technology and just-in-time supply chains means that certain workers must be able to access certain sites, facilities, and assets to ensure continuity of functions. 

7. Government employees, such as emergency managers, and the business community need to establish and maintain lines of communication. 

8. When government and businesses engage in discussions about essential critical infrastructure workers, they need to consider the implications of business operations beyond the jurisdiction where the asset or facility is located. Businesses can have sizeable economic and societal impacts as well as supply chain dependencies that are geographically distributed. 

9. Whenever possible, jurisdictions should align access and movement control policies related to critical infrastructure workers to lower the burden of workers crossing jurisdictional boundaries.