Breakfast. 7:00 a.m. 8:00 a.m.

Transcription

1 Breakfast 7:00 a.m. 8:00 a.m.

2 Opening Announcements NERC 2015 Standards and Compliance Spring Workshop April 3, 2015

3 NERC Antitrust Compliance Guidelines It is NERC s policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition. This policy requires the avoidance of any conduct that violates, or that might appear to violate, the antitrust laws. Among other things, the antitrust laws forbid any agreement between or among competitors regarding prices, availability of service, product design, terms of sale, division of markets, allocation of customers or any other activity that unreasonably restrains competition. 2 RELIABILITY ACCOUNTABILITY

4 Public Announcement Participants are reminded that this meeting is public. Notice of the meeting was posted on the NERC website and widely distributed. The notice included the number for dial-in participation. Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities. 3 RELIABILITY ACCOUNTABILITY

5 General Announcements Westin-Meeting Wi-Fi Code: NERCWB 4 RELIABILITY ACCOUNTABILITY

6 Today s Agenda 8:15 9:15 a.m.: Overview of Stakeholder Guidance on Standards Associated with Risk Elements 9:15 9:30 a.m.: Legal and Regulatory Update 9:30 10:45 a.m.: CIP Cyber Security Standards 10:45 11:00 a.m.: Break 11:00 11:30 a.m.: 2015 and Beyond 11:30 Noon: Miscellaneous Q&A and Closing Remarks 5 RELIABILITY ACCOUNTABILITY

7 6 RELIABILITY ACCOUNTABILITY

8 Guidance on Standards Associated with Risk Elements Marisa Hecht, Senior Advisor, Compliance Assurance Ed Kichline, Senior Counsel, Associate Director of Enforcement 2015 Standards & Compliance Spring Workshop April 3, 2015

9 Overview Purpose Background What are Risk Elements? Risk Elements Development Process Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan 2015 Risk Elements Webinar Series Focus on COM-002-2, Requirement R2 2 RELIABILITY ACCOUNTABILITY

10 Purpose Educate stakeholders on role of Risk Elements in compliance monitoring Introduce webinar series that will provide helpful best practices regarding standards and requirements associated with Risk Elements 3 RELIABILITY ACCOUNTABILITY

11 Background Annual Implementation Plan tailored to risk-based approach to CMEP Replacement of a static, one-size-fits-all list of Reliability Standards, Actively Monitored List (AML) Risk focus areas AML Audit Scope Monitoring plan reflects risk focus areas and Inherent Risk Assessment (IRA) and Internal Controls Evaluation (ICE) processes Removal of six-year audit cycles Three-year cycles remain for BA, RC, and TOP Regional Entities (REs) will determine compliance oversight plan for other registered entities o Use existing CMEP tools 4 RELIABILITY ACCOUNTABILITY

12 What are Risk Elements? First step in Risk-based Compliance Oversight Framework Identification and prioritization of enterprise-wide risks Potential impact to the reliability of the Bulk Power System (BPS) Risk Elements map to Reliability Standards Replace prior actively monitored lists REs also consider Region-specific risks 5 RELIABILITY ACCOUNTABILITY

13 What are Risk Elements? Risk-based Compliance Oversight Framework (Framework) 6 RELIABILITY ACCOUNTABILITY

14 What are Risk Elements? Assessment of Risk Elements occurs at least annually Revised as needed Supports Regional assessment of risks Input into the annual ERO CMEP Implementation Plan 7 RELIABILITY ACCOUNTABILITY

15 Risk Elements Development Process Steps to identify risks outlined in the Risk Elements Guide Includes areas of focus and associated Reliability Standards 8 RELIABILITY ACCOUNTABILITY

16 Risk Elements Development Process Collect the ERO Enterprise data. Develop a matrix and prioritize reliability risks. Identify an effective body of Reliability Standards related to the risks. Select a sub-set of risks for additional focus based on significance and existence of Reliability Standards for that risk Identify the specific Requirements related to their management of risk. Consider additional factors and remove Requirements not appropriate for additional focus Review functional entities to determine their importance to the remaining Requirements Consider Requirements and functional entities remaining and determine if any additional guidance should be provided to CEAs Post Implementation Plan in September each year. 9 RELIABILITY ACCOUNTABILITY

17 CMEP Implementation Plan Purpose Annual operating plan for NERC and the REs Implementation of risk-based approach for CMEP activities NERC release on or about September 1 of preceding year REs submit Regional IPs on or about October 1 NERC reviews and posts revised IP in November to include RE IPs RE IPs subject to review and approval by NERC Updates occur throughout implementation year, as needed 10 RELIABILITY ACCOUNTABILITY

18 CMEP Implementation Plan CMEP IP provides details on: ERO Enterprise s Risk-based Compliance Oversight Framework Prioritized list of Enterprise-wide risk focus areas o Map to associated Reliability Standards o Do not include all potential risks to BPS o REs consider local risks and circumstances within regional footprint Guidance on Regional Risk Assessments Enforcement activities o Compliance exceptions o Self-logging program 11 RELIABILITY ACCOUNTABILITY

19 Regional CMEP Implementation Plans Consider ERO Enterprise risk focus areas Risks identified in the ERO CMEP IP Regional risks Explain how regional risks were identified Including why risk elements in the ERO CMEP IP are not included 12 RELIABILITY ACCOUNTABILITY

20 Key Takeaways Regional IPs provide further detail on risk focus areas and compliance oversight plans REs tailor compliance oversight plans for registered entities REs are at varying stages of implementing IRA and ICE processes NERC oversight and continued training will help ensure consistency 13 RELIABILITY ACCOUNTABILITY

21 2015 Risk Elements Nine areas of focus for 2015 consideration 1. Infrastructure maintenance 2. Uncoordinated protection systems 3. Protection systems misoperations 4. Workforce capability 5. Monitoring and situational awareness 6. Long term planning and system analysis 7. Threats to cyber systems 8. Human error 9. Extreme physical events 14 RELIABILITY ACCOUNTABILITY

22 Webinar Series Highlights one Risk Element Provides training on associated standards Third Thursday of every month starting in April Starts at 1 pm Eastern 15 RELIABILITY ACCOUNTABILITY

23 Webinar Series Subject Date Uncoordinated Protection Systems April 16, 2015 Monitoring and Situational Awareness May 21, 2015 Infrastructure Maintenance June 18, 2015 Protection System Misoperation July 16, 2015 Workforce Capability August 20, 2015 Long Term Planning and System Analysis September 17, 2015 Extreme Physical Events October 15, 2015 Threats to Cyber Systems November 19, RELIABILITY ACCOUNTABILITY

24 Webinar Series 17 RELIABILITY ACCOUNTABILITY

25 Resources 2015 ERO CMEP IP located on NERC website at: tive/final_2015%20cmep%20ip_v7_ pdf Risk Elements Guide for Development of the 2015 CMEP IP located at: tive/final_riskelementsguide_ pdf RAI website for activities and updates: Initiative.asp 18 RELIABILITY ACCOUNTABILITY

26 2015 Risk Element: Human Error Marisa Hecht, Senior Advisor, Compliance Assurance Ed Kichline, Senior Counsel, Associate Director of Enforcement Spring 2015 Standards & Compliance Workshop April 3, 2015

27 2015 Risk Element: Human Error 20 RELIABILITY ACCOUNTABILITY

28 2015 Risk Element: Human Error Inputs ERO Priorities: RISC Updates and Recommendations Organizational or management challenges contribute to operational error Communication errors ERO Top Priority Reliability Risks report Human error appropriately addressed Need for continued attention 21 RELIABILITY ACCOUNTABILITY

29 2015 Risk Element: Human Error Communications Effective communication reduces errors Clear communications enable effective operations COM standards developed to address communications Operating Committee developed best practices for communications 22 RELIABILITY ACCOUNTABILITY

30 2015 Risk Element: Human Error COM Top Violated Serious Risk Standards (by date of filing) 23 RELIABILITY ACCOUNTABILITY

31 2015 Risk Element: Human Error COM-002-2, Requirement R2 24 RELIABILITY ACCOUNTABILITY

32 2015 Risk Element: Human Error Three-part Communication Emergency vs. Routine Operations When reliability matters, ensure effective communication Routine Operating Instructions Considerations Expected use Introductory phrase Script Internal Procedures or Policies Who When How 25 RELIABILITY ACCOUNTABILITY

33 2015 Risk Element: Human Error Common Challenges Sender/receiver identification Distracted receiver Too much information or multiple actions Not enough information No explicit verification of receiver s understanding Clarification not requested Receiver acting before communication is complete Receiver not using tools (e.g. writing down) to remember Too quiet or poor enunciation 26 RELIABILITY ACCOUNTABILITY

34 2015 Risk Element: Human Error Best Practices Clear policies and procedures Elements of effective communication Etiquette Opening phrase Acknowledgement Content Training Performance Assessment Aids to Communication 27 RELIABILITY ACCOUNTABILITY

35 2015 Risk Element: Human Error Controls Example Feedback to operators on improving 3 part communication Shift supervisor regularly listens to the tapes to verify 3 part communication All directives recorded on tapes Operator consoles have a visual reminder to use 3 part communication Operators use 3 part communication for all information exchange and not just directives Operators trained regularly on 3 part communication 28 3 part communication process is clearly established RELIABILITY ACCOUNTABILITY

36 2015 Risk Element: Human Error Examples of Documentation Related to R2 Processes, procedures, or job description that direct need for three-part communication Evidence of implementation (e.g., training curriculum, training records) Summary of incidents where directives were issued Evidence of internal controls E.g., periodic monitoring of voice communications and feedback to personnel) Sample audio recordings Sample system operator logs Verify three-part communications 29 RELIABILITY ACCOUNTABILITY

37 2015 Risk Element: Human Error COM Update Requires the following: Documented communications protocols Training Assessment of adherence to protocols and effectiveness Three-part communication for Operating Instruction during Emergency Adopted by NERC Board of Trustees May 7, 2014 Filed at FERC May 14, 2014 Effective date 12 months after regulatory approval or after Board adoption, as applicable 30 RELIABILITY ACCOUNTABILITY

38 Resources Registration for Risk Elements Webinar Series: Operating Committee - Verbal Communications Industry Practices: Approved_COM-002-2%20Guideline_ _For%20Posting_w%20line%20numbers_Clean_Version%202.pdf 31 RELIABILITY ACCOUNTABILITY

39 32 RELIABILITY ACCOUNTABILITY

40 Legal & Regulatory Update Andrew Wills, NERC Associate Counsel 2015 Standards and Compliance Spring Workshop April 3, 2015

41 Cyber Security Standards: Version 5 Revisions Scott Mix, CISSP Spring 2015 Standards and Compliance Workshop April 3, 2015

42 Overview of Development Activities The Team Standard Drafting Team (SDT) appointed to address these revisions in Project Maggy Powell, Exelon Philip Huff, AECC David Revill, GTC Jay Cribb, Southern Company Forrest Krigbaum, BPA David Dockery, AECI Greg Goodrich, NYISO Christine Hasha, ERCOT Steve Brain, Dominion Scott Saunders, SMUD 2 RELIABILITY ACCOUNTABILITY

43 CIP Standards Version 5 CIP *: BES Cyber Asset and BES Cyber System Categorization CIP-003-6**: Security Management Controls CIP-004-6**: Personnel and Training CIP-005-5: Electronic Security Perimeter(s) CIP-006-6: Physical Security of BES Cyber Systems CIP-007-6**: Systems Security Management * - Changed Devices to Systems in background section ** - Developed as version 7 3 RELIABILITY ACCOUNTABILITY

44 CIP Standards Version 5 CIP-008-5: Incident Reporting and Response Planning CIP-009-6: Recovery Plans for BES Cyber Assets and Systems CIP-010-2***: Configuration Management and Vulnerability Assessments CIP-011-2***: Information Protection *** - Developed as version 3 4 RELIABILITY ACCOUNTABILITY

45 Overview of Development Activities Key Objectives Four directive areas One year filing deadline Outreach during development and comment period 5 RELIABILITY ACCOUNTABILITY

46 FERC Final Rule Issued November 3, 2013 Effective February 3, 2014 Four directives: Identify Assess and Correct language Communication Networks Low Impact BES Cyber Systems Transient Devices First two had one-year deadline Filing deadline February 3, RELIABILITY ACCOUNTABILITY

47 Identify, Assess, and Correct FERC preferred to not have compliance language included within technical requirement SDT responded by deleting language from 17 requirements RAI (Risk-based Compliance Monitoring and Enforcement) concepts replaced need for IAC language 7 RELIABILITY ACCOUNTABILITY

48 Communication Networks FERC Directed creation of definition of communication networks and requirements to address issues: Locked wiring closets Disconnected or locked spare jacks Protection of cabling by conduit or cable trays 8 RELIABILITY ACCOUNTABILITY

49 Communication Networks SDT responded by adding CIP-006 Part 1.10 to address protections of non programmable components of communication networks that are inside an ESP, but outside of a PSP SDT also modified CIP-007 Part 1.2 to address unused physical ports on nonprogrammable communication components and devices at high and medium impact Control Centers Formal definition determined by SDT to be unnecessary at this time 9 RELIABILITY ACCOUNTABILITY

50 Transient Devices Described in Final Rule as devices connected for less than 30-days (USB, laptop, etc) FERC directed modifications to address the following concerns: Device authorization Software authorization Security patch management Malware prevention Unauthorized physical access Procedures for connecting to different impact level systems 10 RELIABILITY ACCOUNTABILITY

51 Transient Devices SDT developed two additional definitions Removable Media Transient Cyber Assets Added CIP-010 Requirement R4 dealing with issue Detailed requirements in attachment and measures in a separate attachment Separated into three areas: o Transient Cyber Assets managed by Responsible Entity o Transient Cyber Assets managed by other parties o Removable Media Modified CIP-004 Part 2.1 to address training on risks associated with Transient Cyber Assets and Removable Media 11 RELIABILITY ACCOUNTABILITY

52 Transient Cyber Assets Transient Cyber Asset: A Cyber Asset that (i) is capable of transmitting or transferring executable code, (ii) is not included in a BES Cyber System, (iii) is not a Protected Cyber Asset (PCA), and (iv) is directly connected (e.g., using Ethernet, serial, Universal Serial Bus, or wireless, including near field or Bluetooth communication) for 30 consecutive calendar days or less to a BES Cyber Asset, a network within an ESP, or a PCA. Examples include, but are not limited to, Cyber Assets used for data transfer, vulnerability assessment, maintenance, or troubleshooting purposes. 12 RELIABILITY ACCOUNTABILITY

53 Transient Cyber Assets (continued) Removable Media: Storage media that (i) are not Cyber Assets, (ii) are capable of transferring executable code, (iii) can be used to store, copy, move, or access data, and (iv) are directly connected for 30 consecutive calendar days or less to a BES Cyber Asset, a network within an ESP, or a Protected Cyber Asset. Examples include, but are not limited to, floppy disks, compact disks, USB flash drives, external hard drives, and other flash memory cards/drives that contain nonvolatile memory. 13 RELIABILITY ACCOUNTABILITY

54 Low Impact BES Cyber Systems FERC concerned with lack of objective criteria for evaluating Low Impact protections Introduces unacceptable level of ambiguity and potential inconsistency into the compliance process Open to alternative approaches the criteria NERC proposes for evaluating a responsible entities protections for Low impact facilities should be clear, objective and commensurate with their impact on the system, and technically justified. No detailed inventory required list of locations / Facilities OK 14 RELIABILITY ACCOUNTABILITY

55 Low Impact BES Cyber Systems (continued) SDT maintained all low impact requirements in CIP-003 Low-only entities only need to comply with CIP-002 and CIP- 003 Added CIP-003 Part 1.2 dealing with security policy for low impact BES Cyber Systems Added Attachments dealing with the technical requirement and measures Kept four original areas 15 RELIABILITY ACCOUNTABILITY

56 Low Impact BES Cyber Systems (continued) Security Awareness reinforce, at least every 15 calendar months, cyber security practices Incident Response Modeled from medium impact 5 elements (of 9: collapsed process requirements and update requirements together; no documentation of deviations or specific record retention but still need to demonstrate compliance) Physical Security control physical access based on need 16 RELIABILITY ACCOUNTABILITY

57 Low Impact BES Cyber Systems (continued) Electronic Security Two new definitions LERC and LEAP Similar to but different from ERC and EAP concepts at medium & high permit only necessary inbound and outbound bi-directional routable protocol access authentication for all Dial-up Connectivity Seven reference model drawings showing LERC & LEAP in Guidelines and Technical Basis section 17 RELIABILITY ACCOUNTABILITY

58 Low Impact BES Cyber Systems (continued) Low Impact External Routable Connectivity (LERC): Direct user-initiated interactive access or a direct device-to-device connection to a low impact BES Cyber System(s) from a Cyber Asset outside the asset containing those low impact BES Cyber System(s) via a bi-directional routable protocol connection. Pointto-point communications between intelligent electronic devices that use routable communication protocols for time-sensitive protection or control functions between Transmission station or substation assets containing low impact BES Cyber Systems are excluded from this definition (examples of this communication include, but are not limited to, IEC GOOSE or vendor proprietary protocols). 18 RELIABILITY ACCOUNTABILITY

59 Low Impact BES Cyber Systems (continued) Low Impact BES Cyber System Electronic Access Point (LEAP): A Cyber Asset interface that controls Low Impact External Routable Connectivity. The Cyber Asset containing the LEAP may reside at a location external to the asset or assets containing low impact BES Cyber Systems. 19 RELIABILITY ACCOUNTABILITY

60 Low Impact BES Cyber Systems (continued) 20 RELIABILITY ACCOUNTABILITY

61 Low Impact BES Cyber Systems (continued) 21 RELIABILITY ACCOUNTABILITY

62 Low Impact BES Cyber Systems (continued) 22 RELIABILITY ACCOUNTABILITY

63 Low Impact BES Cyber Systems (continued) 23 RELIABILITY ACCOUNTABILITY

64 Low Impact BES Cyber Systems (continued) 24 RELIABILITY ACCOUNTABILITY

65 Low Impact BES Cyber Systems (continued) 25 RELIABILITY ACCOUNTABILITY

66 Low Impact BES Cyber Systems (continued) 26 RELIABILITY ACCOUNTABILITY

67 Implementation Plan Phased implementation plan: IAC no change (4/1/16) Communication Networks 9 months after the effective date of the standard Transient Devices 9 months after the effective date of the standard Low Impact o Latter of 4/1/17 or 9 months after the effective date of the standard for policy, plan, security awareness, and response o Latter of 9/1/18 or 9 months after the effective date of the standard for physical and electronic security 27 RELIABILITY ACCOUNTABILITY

68 Current Status NERC Board approved responses to IAC and Communication Networks directives on November 13, 2014 NERC Board approved responses to Low Impact and Transient Device directives on February 12, 2015 Board action adjusted version numbers to -6 and -3 All four directive areas filed with FERC on February 13, 2015 (10- day extension granted due to scheduled NERC board meeting) FERC must go through its approval process 28 RELIABILITY ACCOUNTABILITY

69 Project Development History: CIP Version 5 Revisions page: References Critical-Infrastructure-Protection-Version-5-Revisions.aspx CIP Version 5 Transition page: 29 RELIABILITY ACCOUNTABILITY

70 Questions Scott Mix, CISSP

71 Break 10:45 a.m. 11:00 a.m.

72 2015 & Beyond Valerie Agnew, NERC Senior Director of Standards Ryan Stewart, NERC Manager of Standards Development Marisa Hecht, NERC Senior Advisor of Compliance Assurance 2015 Standards and Compliance Spring Workshop April 3, 2015

73 Closing Remarks Q&A