CIP V5 Updates Midwest Energy Association Electrical Operations Conference May 2015 Bob Yates, CISSP, MBA Principal Technical Auditor ReliabilityFirst Corporation
Agenda Cyber Security Standards Version 5 Revisions Transition Advisory Group Guidance Development 2
CIP Standards Version 5 CIP-002-5.1*: 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 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 * - Changed Devices to Systems in background section ** - Developed as version 7 *** - Developed as version 3 3
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, 2015 4
Identify, Assess, and Correct FERC preferred to not have compliance language included within technical requirement SDT responded by deleting language from 17 requirements Risk-based Compliance Monitoring and Enforcement replaces need for IAC language 5
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 6
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 7
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 8
Transient Devices 9 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: Transient Cyber Assets managed by Responsible Entity Transient Cyber Assets managed by other parties Removable Media Modified CIP-004 Part 2.1 to address training on risks associated with Transient Cyber Assets and Removable Media
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 10
Low Impact BES Cyber Systems 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 11
Low Impact BES Cyber Systems 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 12
Low Impact BES Cyber Systems 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 13
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 Latter of 4/1/17 or 9 months after the effective date of the standard for policy, plan, security awareness, and response Latter of 9/1/18 or 9 months after the effective date of the standard for physical and electronic security 14
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 -2 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 15
Guidance Development Process 16
April 22 CIP V5 Transition Update Discussed the purpose of guidance provided through Lessons Learned and FAQs Guidance Documents Provide explanation of effective implementation approaches of topics Identified during transition period Lessons Learned Increased technical discussion and analysis FAQs Questions with shorter more basic responses 17
April 22 CIP V5 Transition Update Discussed five topics not appropriately addressed through a lesson learned or FAQ Not consistent with the purpose of those guidance documents Related to questions regarding the meaning of a particular requirement NERC posted separate documents that discuss each of these issues and the manner in which NERC understands the relevant requirement or NERC Glossary term, as informed by the plain language of and the record of development for the CIP version 5 standards 18
Lesson Learned Status Far-end Relay Generation Segmentation Mixed Trust EACMs Interactive Remote Access Grouping of BES Cyber Systems Virtualization (Networks and Servers) 19
Lesson Learned Status Far-end Relay (AKA Transfer-Trip) Status: Approved by Standards Committee and Posted as Final. The far-end relay does not automatically inherit a Medium impact categorization if the near-end substation satisfies the qualifications of Criterion 2.5. 20
Lesson Learned Status Generation Segmentation Status: Approved by Standards Committee and Posted as Final. BES Cyber Systems associated with a generating plant in excess of 1500 MW Net Real Power Capability can be segmented such that there are no Medium impacting BES Cyber Systems. Includes a discussion of evidence required to demonstrate sufficient segregation. 21
Lesson Learned Status Mixed Trust Electronic Access Control or Monitoring Systems Status: Addressing industry comments The issue is whether corporate resources (Active Directory servers, remote access authentication servers, log servers, Intrusion Detection Systems, etc.) supporting both corporate and Electronic Security Perimeter access control are Electronic Access Control or Monitoring Systems. Current position is that if the Cyber Asset is providing electronic access control or monitoring support to the CIP environment, the Cyber Asset is an EACMS for the purposes of CIP compliance. 22
Lesson Learned Status Interactive Remote Access Status: Addressing industry comments provide guidance on implementing security controls for the use of Interactive Remote Access. Open question is whether scripts under programmatic control and actions performed by management consoles constitute Interactive Remote Access. 23
Lesson Learned Status Grouping of BES Cyber Systems Status: Addressing industry comments Purpose is to describe useful methods to group BES Cyber Assets into BES Cyber Systems (BCS). 24
Lesson Learned Status Virtualization (Networks and Servers) Status: To be issued as a Lessons Learned in May The concern with virtualization is when there is a mixed trust environment The standards do not due a good job of addressing the technology For virtual servers where a mixed trust environment is being used there will be a lot of scrutiny of security controls in place For networks using mixed trust will need to see that the appropriate Electronic Access Point Controls are in place for the device 25
FAQs 3 are already posted on the V5 Transition Program page on the NERC web site as Technical FAQs 34 FAQs were posted for industry comment April 2 with comments due back by May 15 13 FAQs were posted for industry comment May 1 with comments due back by June 15 26
NERC Communications Impact Rating Criteria 2.3 and 2.6 Impact rating for generation interconnections Facilities Programmable Electronic Devices Network and Externally Accessible Devices Control Centers and functional obligations 27
NERC Communications Impact Rating Criteria 2.3 and 2.6 Status: Issued as NERC Communication on April 22, 2015 Learned For IRC 2.3 and 2.6 Reliability Coordinator, Planning Coordinator, or Transmission Planner addresses the facility (generation or transmission) The asset owning registered entity must then determine which BES Cyber Assets or BES Cyber Systems support the identified Facility 28
NERC Communications Impact rating for generation interconnections Facilities Status: Issued as NERC Communication on April 22, 2015 Learned The question is whether a generator lead line should be included in the aggregate weighted value calculation under Criterion 2.5 Impact Rating Criteria. Consistent with the language of Criterion 2.5 and the Guidelines and Technical Basis section of CIP-002-5.1, a radial generator lead line with no network flows (i.e., no power would flow through the line if the generator is off-line) and with the sole purpose of connecting generator output to a networked Transmission system would not qualify as a Transmission line to be included in the Criterion 2.5 calculation. 29
NERC Communications Programmable Electronic Devices (PED) Status: Issued as NERC Communication on April 22, 2015 Learned some entities, including the Implementation Study participants, requested further clarification on the meaning of the phrase programmable electronic device, which is not defined in the NERC Glossary. Record of development indicates that the CIP version 5 SDT intended a programmable electronic device to be any device that is electronic and capable of executing a set of instructions. Nothing in the Cyber Asset definition or the development record indicates that the SDT sought to exclude configurable-only devices or distinguish between Cyber Assets that are physically programmable as opposed to remotely programmable via cyber means. 30
NERC Communications Network and Externally Accessible Devices Status: Issued as NERC Communication on April 22, 2015 Learned Does the definition of a BES Cyber Asset ( BCA ) include network devices, such as routers, core network switches, communication processers, modems, front-end processors, and data concentrators? o Under the plain language of the BCA definition, entities cannot categorically exclude network devices from the definition of BCA but must evaluate the reliability impact of the network device to determine whether it meets the BCA definition. A BCA is defined in the NERC Glossary as follows: 31
NERC Communications Network and Externally Accessible Devices (cont.) Does the scope of the exemption for Cyber Assets associated with communication networks and data communication links between Electronic Security Perimeters cover network devices with routable connectivity that would otherwise meet the BCA definition and be included in an Electronic Security Perimeter (ESP)? Is there an exemption for similar Cyber Assets associated with non-routable communication networks and data communication links? o Because the exemption applies to devices between ESPs, which are typically owned and operated by third parties, the exemption does not apply to network devices that meet the BCA definition and would otherwise be required to reside in an ESP. o NERC will exercise its discretion to exempt any Cyber Assets associated with non-routable communication networks/links that would be exempt if they were routable communication between discrete ESPs. 32
NERC Communications Network and Externally Accessible Devices (cont.) Are the requirements applicable to BES Cyber Systems (BCS) with routable connectivity (i.e., requirements related to having an ESP and External Routable Connectivity (ERC)) applicable to a natively serial-based (non-routable) BCA that has been modified to be externally accessible via a routable network? o serial device is plugged into the converter such that accessing the serial device is achieved not point to point, but via a network address, the converter s address, and a unique port number assigned to the serial device. In such cases, the natively serial-based device now has a unique routable network address and an associated network address. 33
NERC Communications Control Centers and functional obligations Status: Issued as NERC Communication on April 22, 2015 Learned High Impact Rating (H) - 1.3 Each Control Center or backup Control Center used to perform the functional obligations of the Transmission Operator for one or more of the assets that meet criterion 2.2, 2.4, 2.5, 2.7, 2.8, 2.9, or 2.10. Medium Impact Rating (M) - 2.12. Each Control Center or backup Control Center used to perform the functional obligations of the Transmission Operator not included in High Impact Rating (H), above. Went back to the official record of the Standard Drafting Team and determined it was clearly addressed that the SDT intent was the functions you are performing and not how you are registered. 34
References Project 2014-02 Development History: CIP Version 5 Revisions page: http://www.nerc.com/pa/stand/pages/project-2014-xx- Critical-Infrastructure-Protection-Version-5-Revisions.aspx CIP Version 5 Transition page: http://www.nerc.com/pa/ci/pages/transition-program.aspx 35
Questions & Answers Forward Together ReliabilityFirst 36