CIP Standards Development Overview
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- Iris Perkins
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1 CIP Standards Development Overview CSSDTO706 Meeting with FERC Technical Staff July 28, 2011
2 Objectives Historical Timeline CIP CIP CIP Version 5 2
3 Project Overview FERC Order 706 SDT appointed August 2008 CIP Version 2 September 2009 CIP Version 3 March 2010 CIP Version 4 Ongoing Effort 3
4 CSO706 SDT Members 17 members almost all asset owners Representation from IOUs, US and Canadian Government, Cooperatives, Municipals, Independent Power Producers, and ISO/RTO Worked together for 3 years Monthly face-to-face meetings, several interim conference calls and multiple webinars/workshops Worked through 3 successful ballots 4
5 CIP Overview Version 4 of the CIP Standards Approved by Industry December 30, 2010 Submitted to FERC February 10, ,232 page filing 0.pdf Filing included CIP through CIP-009-4, but only changes in CIP
6 CIP Overview (cont.) Replaces risk-based assessment methodology with bright-line criteria Still maintains the concept of Critical Asset and Critical Cyber Asset Uniform application across all entities and regions Eliminates subjectivity by entities over what is critical 17 defined criteria To the greatest extent possible, bright line criteria tied to operational standards 6
7 CIP Applicability 4.2. The following are exempt from Standard CIP-002-4: Facilities regulated by the Canadian Nuclear Safety Commission Cyber Assets associated with communication networks and data communication links between discrete Electronic Security Perimeters Cyber Assets associated with Cyber Security Plans submitted to and verified by the U. S. Nuclear Regulatory Commission pursuant to 10 C.F.R. Section
8 CIP Effective Date Effective Date: The first day of the eighth calendar quarter after applicable regulatory approvals have been received (or the Reliability Standard otherwise becomes effective the first day of the ninth calendar quarter after BOT adoption in those jurisdictions where regulatory approval is not required) 8
9 CIP Requirement R1 R1. Critical Asset Identification The Responsible Entity shall develop a list of its identified Critical Assets determined through an annual application of the criteria contained in CIP Attachment 1 Critical Asset Criteria. The Responsible Entity shall update this list as necessary, and review it at least annually. 9
10 CIP Requirement R2 R2. Critical Cyber Asset Identification Using the list of Critical Assets developed pursuant to Requirement R1, the Responsible Entity shall develop a list of associated Critical Cyber Assets essential to the operation of the Critical Asset. The Responsible Entity shall update this list as necessary, and review it at least annually. For each group of generating units (including nuclear generation) at a single plant location identified in Attachment 1, criterion 1.1, the only Cyber Assets that must be considered are those shared Cyber Assets that could, within 15 minutes, adversely impact the reliable operation of any combination of units that in aggregate equal or exceed Attachment 1, criterion
11 CIP Requirement R3 R3. Annual Approval The senior manager or delegate(s) shall approve annually the list of Critical Assets and the list of Critical Cyber Assets. Based on Requirements R1 and R2 the Responsible Entity may determine that it has no Critical Assets or Critical Cyber Assets. The Responsible Entity shall keep a signed and dated record of the senior manager or delegate(s) s approval of the list of Critical Assets and the list of Critical Cyber Assets (even if such lists are null.) 11
12 Remote Access UA Implements requirements on Cyber Assets used for monitoring or support of Critical Cyber Assets when communication is initiated from outside an Electronic Security Perimeter i.e., remote laptop or desktop systems accessing Critical Cyber Assets, but not for the purpose of control Remote access for the purpose of control is the subject of CAN-0005 Development now integrated into CIP Version 5 12
13 CIP V5 The Drafting Team continues to work to address the remaining issues in Order 706 Using the CIP-002 to CIP organization Monthly meetings and many conference calls Initial ballot by December 2011 The Drafting Team developed a set of development goals 13
14 Development Goals Goal 1: To address the remaining Requirements-related directives from all CIP related FERC orders, all approved interpretations, and CAN topics within applicable existing requirements. Goal 2: To develop consistent identification criteria of BES Cyber Systems and application of cyber security requirements that are appropriate for the risk presented to the BES. Goal 3: To provide guidance and context for each Standard Requirement Goal 4: To leverage current stakeholder investments used for complying with existing CIP requirements. Goal 5: To minimize technical feasibility exceptions. Goal 6: To develop requirements that foster a culture of security and due diligence in the industry to complement a culture of compliance. Goal 7: To develop a realistic and comprehensible implementation plan for the industry. 14
15 Levels of impact High Impact Large Control Centers CIP-003 through 009+ Medium Impact Generation and Transmission Other Control Centers Similar to CIP-003 to 009 v4 All other BES Cyber Systems Security Policy Security Awareness Incident Response Boundary Protection 15
16 Example Format 16
17 Requirement Filters Why are we doing this? What do we hope to accomplish? What security concept are we trying to implement? If these questions cannot be answered, is the requirement necessary? Is it absolutely necessary to be done only this way to protect the BES? Are there other ways of accomplishing this requirement? If so, the requirement may be too specific. Is the timeframe arbitrary? Is the desired outcome clear and unambiguous? Can the measure clarify the desired outcome? 17
18 Questions?
19 Thank you
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