From the EnergySec website:

"EnergySec published comments on the Transmission Owners Control Center and Virtualizations white papers the Standards Drafting Team is seeking comments on. Since EnergySec does not formally vote on SDT ballot issues, we are not formally submitting these comments to the SDT. However, we are making them available for our members to use or revise as they see fit. The documents are available in the Members section of the EnergySec Community wiki."

Not only are they not formally submitted, it would appear that almost no one on the SDT or the NERC staff associated with it actually has access to read it. You would think that something like this would be more use to their membership if it were not behind a pay wall.