© cyber security consulting - all rights reserved understanding the nerc critical infrastructure...

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© Cyber SECurity Consulting - All rights reserved www.industryconsulting.org Understanding the NERC Understanding the NERC Critical Infrastructure Protection ritical Infrastructure Protection (CIP-002 through CIP-009) Standards CIP-002 through CIP-009) Standards William T. Shaw PhD, CISSP Principal – Cyber SECurity Consulting Cyber SECurity Consulting

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Page 1: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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wwwindustryconsultingorg

Understanding the NERC Understanding the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

William T Shaw PhD CISSPPrincipal ndash Cyber SECurity ConsultingCyber SECurity Consulting

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Understanding the NERC StandardsUnderstanding the NERC Standards

The general objective of the NERC CIP standards are to insure that computer automation systems and

communication networks essential to the reliable supply of electric power to the nation are reasonably protected

against attacks from a range of credible threat sources and that a sustaining program is established to maintain the

viability and effectiveness of such protections

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The ThreatThe Threat

A terrorist attack on electrical infrastructure that causes widespread long-term power outages which result in health and human safety impacts economic impacts damage to other civil military and industrial infrastructure and opens up security vulnerabilities

Physical attacksbull Damagedestroy key facilitiesbull Invade and take control of key facilities

Cyber (Electronic) attacksbull Disabledisrupt critical systemsbull Take control of critical systemsbull Corrupt critical systems

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A Brief TimelineA Brief Timeline

911

-200

1 A

ttac

ksW

hite

hous

e Is

sues

Dire

ctiv

es

DH

S I

ssue

s D

irect

ives

NE

RC

rel

ease

s U

AS

-12

00N

orth

east

Bla

ckou

t oc

curs

NE

RC

upd

ates

to

1300

NE

RC

rev

ises

as

CIP

sN

ER

C d

esig

nate

d E

RO

FE

RC

man

date

s C

IPs

20012002

20032004

20052006

20072008

20092010

Today

Mus

t be

aud

itabl

y co

mpl

iant

Three years

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Evolution of the StandardsEvolution of the Standards

NERC 1200 =gt 1300 Standard requirements1201 Cyber Security Policy1201 Cyber Security Policy

1202 Critical Cyber Assets1202 Critical Cyber Assets

1203 Electronic Security Perimeter1203 Electronic Security Perimeter

1204 Electronic Access Controls1204 Electronic Access Controls

1205 Physical Security Perimeter1205 Physical Security Perimeter

1206 Physical Access Controls1206 Physical Access Controls

1207 Personnel1207 Personnel

1208 Monitoring Physical Access1208 Monitoring Physical Access

1209 Monitoring Electronic Access1209 Monitoring Electronic Access

1210 Information Protection1210 Information Protection

1211 Training1211 Training

1212 Systems Management1212 Systems Management

1213 Test Procedures1213 Test Procedures

1214 Electronic Incident Response Actions1214 Electronic Incident Response Actions

1215 Physical Incident Response Actions1215 Physical Incident Response Actions

1216 Recovery Plans1216 Recovery Plans

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

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Evolution of the StandardsEvolution of the Standards

NERC 1300 =gt CIPs Standard requirements

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

CIP 001 Sabotage ReportingCIP 001 Sabotage Reporting

CIP 002 Critical Cyber AssetsCIP 002 Critical Cyber Assets

CIP 003 Security Management ControlsCIP 003 Security Management Controls

CIP 004 Personnel amp TrainingCIP 004 Personnel amp Training

CIP 005 Electronic SecurityCIP 005 Electronic Security

CIP 006 Physical Security of CCACIP 006 Physical Security of CCA

CIP 007 Systems Security ManagementCIP 007 Systems Security Management

CIP 008 Incident ReportingResponse PlanningCIP 008 Incident ReportingResponse Planning

CIP 009 Recovery Plans for CCACIP 009 Recovery Plans for CCA

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Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

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Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

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G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

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ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

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Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 2: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC StandardsUnderstanding the NERC Standards

The general objective of the NERC CIP standards are to insure that computer automation systems and

communication networks essential to the reliable supply of electric power to the nation are reasonably protected

against attacks from a range of credible threat sources and that a sustaining program is established to maintain the

viability and effectiveness of such protections

copy Cyber SECurity Consulting - All rights reserved

The ThreatThe Threat

A terrorist attack on electrical infrastructure that causes widespread long-term power outages which result in health and human safety impacts economic impacts damage to other civil military and industrial infrastructure and opens up security vulnerabilities

Physical attacksbull Damagedestroy key facilitiesbull Invade and take control of key facilities

Cyber (Electronic) attacksbull Disabledisrupt critical systemsbull Take control of critical systemsbull Corrupt critical systems

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A Brief TimelineA Brief Timeline

911

-200

1 A

ttac

ksW

hite

hous

e Is

sues

Dire

ctiv

es

DH

S I

ssue

s D

irect

ives

NE

RC

rel

ease

s U

AS

-12

00N

orth

east

Bla

ckou

t oc

curs

NE

RC

upd

ates

to

1300

NE

RC

rev

ises

as

CIP

sN

ER

C d

esig

nate

d E

RO

FE

RC

man

date

s C

IPs

20012002

20032004

20052006

20072008

20092010

Today

Mus

t be

aud

itabl

y co

mpl

iant

Three years

copy Cyber SECurity Consulting - All rights reserved

Evolution of the StandardsEvolution of the Standards

NERC 1200 =gt 1300 Standard requirements1201 Cyber Security Policy1201 Cyber Security Policy

1202 Critical Cyber Assets1202 Critical Cyber Assets

1203 Electronic Security Perimeter1203 Electronic Security Perimeter

1204 Electronic Access Controls1204 Electronic Access Controls

1205 Physical Security Perimeter1205 Physical Security Perimeter

1206 Physical Access Controls1206 Physical Access Controls

1207 Personnel1207 Personnel

1208 Monitoring Physical Access1208 Monitoring Physical Access

1209 Monitoring Electronic Access1209 Monitoring Electronic Access

1210 Information Protection1210 Information Protection

1211 Training1211 Training

1212 Systems Management1212 Systems Management

1213 Test Procedures1213 Test Procedures

1214 Electronic Incident Response Actions1214 Electronic Incident Response Actions

1215 Physical Incident Response Actions1215 Physical Incident Response Actions

1216 Recovery Plans1216 Recovery Plans

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

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Evolution of the StandardsEvolution of the Standards

NERC 1300 =gt CIPs Standard requirements

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

CIP 001 Sabotage ReportingCIP 001 Sabotage Reporting

CIP 002 Critical Cyber AssetsCIP 002 Critical Cyber Assets

CIP 003 Security Management ControlsCIP 003 Security Management Controls

CIP 004 Personnel amp TrainingCIP 004 Personnel amp Training

CIP 005 Electronic SecurityCIP 005 Electronic Security

CIP 006 Physical Security of CCACIP 006 Physical Security of CCA

CIP 007 Systems Security ManagementCIP 007 Systems Security Management

CIP 008 Incident ReportingResponse PlanningCIP 008 Incident ReportingResponse Planning

CIP 009 Recovery Plans for CCACIP 009 Recovery Plans for CCA

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Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

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Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

copy Cyber SECurity Consulting - All rights reserved

G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

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ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

copy Cyber SECurity Consulting - All rights reserved

Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

copy Cyber SECurity Consulting - All rights reserved

Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

copy Cyber SECurity Consulting - All rights reserved

CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

copy Cyber SECurity Consulting - All rights reserved

CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

copy Cyber SECurity Consulting - All rights reserved

ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

copy Cyber SECurity Consulting - All rights reserved

Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

copy Cyber SECurity Consulting - All rights reserved

CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

copy Cyber SECurity Consulting - All rights reserved

Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 3: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

The ThreatThe Threat

A terrorist attack on electrical infrastructure that causes widespread long-term power outages which result in health and human safety impacts economic impacts damage to other civil military and industrial infrastructure and opens up security vulnerabilities

Physical attacksbull Damagedestroy key facilitiesbull Invade and take control of key facilities

Cyber (Electronic) attacksbull Disabledisrupt critical systemsbull Take control of critical systemsbull Corrupt critical systems

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A Brief TimelineA Brief Timeline

911

-200

1 A

ttac

ksW

hite

hous

e Is

sues

Dire

ctiv

es

DH

S I

ssue

s D

irect

ives

NE

RC

rel

ease

s U

AS

-12

00N

orth

east

Bla

ckou

t oc

curs

NE

RC

upd

ates

to

1300

NE

RC

rev

ises

as

CIP

sN

ER

C d

esig

nate

d E

RO

FE

RC

man

date

s C

IPs

20012002

20032004

20052006

20072008

20092010

Today

Mus

t be

aud

itabl

y co

mpl

iant

Three years

copy Cyber SECurity Consulting - All rights reserved

Evolution of the StandardsEvolution of the Standards

NERC 1200 =gt 1300 Standard requirements1201 Cyber Security Policy1201 Cyber Security Policy

1202 Critical Cyber Assets1202 Critical Cyber Assets

1203 Electronic Security Perimeter1203 Electronic Security Perimeter

1204 Electronic Access Controls1204 Electronic Access Controls

1205 Physical Security Perimeter1205 Physical Security Perimeter

1206 Physical Access Controls1206 Physical Access Controls

1207 Personnel1207 Personnel

1208 Monitoring Physical Access1208 Monitoring Physical Access

1209 Monitoring Electronic Access1209 Monitoring Electronic Access

1210 Information Protection1210 Information Protection

1211 Training1211 Training

1212 Systems Management1212 Systems Management

1213 Test Procedures1213 Test Procedures

1214 Electronic Incident Response Actions1214 Electronic Incident Response Actions

1215 Physical Incident Response Actions1215 Physical Incident Response Actions

1216 Recovery Plans1216 Recovery Plans

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

copy Cyber SECurity Consulting - All rights reserved

Evolution of the StandardsEvolution of the Standards

NERC 1300 =gt CIPs Standard requirements

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

CIP 001 Sabotage ReportingCIP 001 Sabotage Reporting

CIP 002 Critical Cyber AssetsCIP 002 Critical Cyber Assets

CIP 003 Security Management ControlsCIP 003 Security Management Controls

CIP 004 Personnel amp TrainingCIP 004 Personnel amp Training

CIP 005 Electronic SecurityCIP 005 Electronic Security

CIP 006 Physical Security of CCACIP 006 Physical Security of CCA

CIP 007 Systems Security ManagementCIP 007 Systems Security Management

CIP 008 Incident ReportingResponse PlanningCIP 008 Incident ReportingResponse Planning

CIP 009 Recovery Plans for CCACIP 009 Recovery Plans for CCA

copy Cyber SECurity Consulting - All rights reserved

Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

copy Cyber SECurity Consulting - All rights reserved

G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

copy Cyber SECurity Consulting - All rights reserved

ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

copy Cyber SECurity Consulting - All rights reserved

Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

copy Cyber SECurity Consulting - All rights reserved

Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

copy Cyber SECurity Consulting - All rights reserved

Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

copy Cyber SECurity Consulting - All rights reserved

CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

copy Cyber SECurity Consulting - All rights reserved

CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

copy Cyber SECurity Consulting - All rights reserved

CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

copy Cyber SECurity Consulting - All rights reserved

ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

copy Cyber SECurity Consulting - All rights reserved

Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 4: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

A Brief TimelineA Brief Timeline

911

-200

1 A

ttac

ksW

hite

hous

e Is

sues

Dire

ctiv

es

DH

S I

ssue

s D

irect

ives

NE

RC

rel

ease

s U

AS

-12

00N

orth

east

Bla

ckou

t oc

curs

NE

RC

upd

ates

to

1300

NE

RC

rev

ises

as

CIP

sN

ER

C d

esig

nate

d E

RO

FE

RC

man

date

s C

IPs

20012002

20032004

20052006

20072008

20092010

Today

Mus

t be

aud

itabl

y co

mpl

iant

Three years

copy Cyber SECurity Consulting - All rights reserved

Evolution of the StandardsEvolution of the Standards

NERC 1200 =gt 1300 Standard requirements1201 Cyber Security Policy1201 Cyber Security Policy

1202 Critical Cyber Assets1202 Critical Cyber Assets

1203 Electronic Security Perimeter1203 Electronic Security Perimeter

1204 Electronic Access Controls1204 Electronic Access Controls

1205 Physical Security Perimeter1205 Physical Security Perimeter

1206 Physical Access Controls1206 Physical Access Controls

1207 Personnel1207 Personnel

1208 Monitoring Physical Access1208 Monitoring Physical Access

1209 Monitoring Electronic Access1209 Monitoring Electronic Access

1210 Information Protection1210 Information Protection

1211 Training1211 Training

1212 Systems Management1212 Systems Management

1213 Test Procedures1213 Test Procedures

1214 Electronic Incident Response Actions1214 Electronic Incident Response Actions

1215 Physical Incident Response Actions1215 Physical Incident Response Actions

1216 Recovery Plans1216 Recovery Plans

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

copy Cyber SECurity Consulting - All rights reserved

Evolution of the StandardsEvolution of the Standards

NERC 1300 =gt CIPs Standard requirements

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

CIP 001 Sabotage ReportingCIP 001 Sabotage Reporting

CIP 002 Critical Cyber AssetsCIP 002 Critical Cyber Assets

CIP 003 Security Management ControlsCIP 003 Security Management Controls

CIP 004 Personnel amp TrainingCIP 004 Personnel amp Training

CIP 005 Electronic SecurityCIP 005 Electronic Security

CIP 006 Physical Security of CCACIP 006 Physical Security of CCA

CIP 007 Systems Security ManagementCIP 007 Systems Security Management

CIP 008 Incident ReportingResponse PlanningCIP 008 Incident ReportingResponse Planning

CIP 009 Recovery Plans for CCACIP 009 Recovery Plans for CCA

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Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

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Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

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G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

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ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

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Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

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2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

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Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 5: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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Evolution of the StandardsEvolution of the Standards

NERC 1200 =gt 1300 Standard requirements1201 Cyber Security Policy1201 Cyber Security Policy

1202 Critical Cyber Assets1202 Critical Cyber Assets

1203 Electronic Security Perimeter1203 Electronic Security Perimeter

1204 Electronic Access Controls1204 Electronic Access Controls

1205 Physical Security Perimeter1205 Physical Security Perimeter

1206 Physical Access Controls1206 Physical Access Controls

1207 Personnel1207 Personnel

1208 Monitoring Physical Access1208 Monitoring Physical Access

1209 Monitoring Electronic Access1209 Monitoring Electronic Access

1210 Information Protection1210 Information Protection

1211 Training1211 Training

1212 Systems Management1212 Systems Management

1213 Test Procedures1213 Test Procedures

1214 Electronic Incident Response Actions1214 Electronic Incident Response Actions

1215 Physical Incident Response Actions1215 Physical Incident Response Actions

1216 Recovery Plans1216 Recovery Plans

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

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Evolution of the StandardsEvolution of the Standards

NERC 1300 =gt CIPs Standard requirements

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

CIP 001 Sabotage ReportingCIP 001 Sabotage Reporting

CIP 002 Critical Cyber AssetsCIP 002 Critical Cyber Assets

CIP 003 Security Management ControlsCIP 003 Security Management Controls

CIP 004 Personnel amp TrainingCIP 004 Personnel amp Training

CIP 005 Electronic SecurityCIP 005 Electronic Security

CIP 006 Physical Security of CCACIP 006 Physical Security of CCA

CIP 007 Systems Security ManagementCIP 007 Systems Security Management

CIP 008 Incident ReportingResponse PlanningCIP 008 Incident ReportingResponse Planning

CIP 009 Recovery Plans for CCACIP 009 Recovery Plans for CCA

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Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

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Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

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G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

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ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

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Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 6: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Evolution of the StandardsEvolution of the Standards

NERC 1300 =gt CIPs Standard requirements

1301 Security Management Controls1301 Security Management Controls

1302 Critical Cyber Assets1302 Critical Cyber Assets

1303 Personnel amp Training1303 Personnel amp Training

1304 Electronic Security1304 Electronic Security

1305 Physical Security1305 Physical Security

1306 Systems Security Management1306 Systems Security Management

1307 Incident Response Planning1307 Incident Response Planning

1308 Recovery Plans1308 Recovery Plans

CIP 001 Sabotage ReportingCIP 001 Sabotage Reporting

CIP 002 Critical Cyber AssetsCIP 002 Critical Cyber Assets

CIP 003 Security Management ControlsCIP 003 Security Management Controls

CIP 004 Personnel amp TrainingCIP 004 Personnel amp Training

CIP 005 Electronic SecurityCIP 005 Electronic Security

CIP 006 Physical Security of CCACIP 006 Physical Security of CCA

CIP 007 Systems Security ManagementCIP 007 Systems Security Management

CIP 008 Incident ReportingResponse PlanningCIP 008 Incident ReportingResponse Planning

CIP 009 Recovery Plans for CCACIP 009 Recovery Plans for CCA

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Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

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Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

copy Cyber SECurity Consulting - All rights reserved

G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

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ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

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Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

copy Cyber SECurity Consulting - All rights reserved

CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

copy Cyber SECurity Consulting - All rights reserved

ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

copy Cyber SECurity Consulting - All rights reserved

Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

copy Cyber SECurity Consulting - All rights reserved

Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

copy Cyber SECurity Consulting - All rights reserved

CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

copy Cyber SECurity Consulting - All rights reserved

SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 7: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Important TermsImportant Terms

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a

(1) significant impact on the ability to serve large quantities of customers for an extended period of time

(2) would have a detrimental impact on the reliability or operability of the Bulk Electric System

(3) or would cause significant risk to public health and safety

Note that when NERC went from the initial 1200 standard to the later 1300 standard Note that when NERC went from the initial 1200 standard to the later 1300 standard (and to the CIPs) one of the major changes was the broadening of the definition of (and to the CIPs) one of the major changes was the broadening of the definition of Critical AssetsCritical Assets to make the definition far more generalized and to put the to make the definition far more generalized and to put the responsibility for specifically identifying those assets into the hands of the responsible responsibility for specifically identifying those assets into the hands of the responsible entities entities

Also note that no specific quantization was provided for ldquolarge quantities of Also note that no specific quantization was provided for ldquolarge quantities of customersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquocustomersrdquo ldquoextended period of timerdquo or ldquosignificant riskrdquo

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Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

copy Cyber SECurity Consulting - All rights reserved

G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

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ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

copy Cyber SECurity Consulting - All rights reserved

Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

copy Cyber SECurity Consulting - All rights reserved

CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

copy Cyber SECurity Consulting - All rights reserved

CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

copy Cyber SECurity Consulting - All rights reserved

CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

copy Cyber SECurity Consulting - All rights reserved

ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

copy Cyber SECurity Consulting - All rights reserved

Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

copy Cyber SECurity Consulting - All rights reserved

CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

copy Cyber SECurity Consulting - All rights reserved

Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

copy Cyber SECurity Consulting - All rights reserved

Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 8: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Cyber Assets Those programmable electronic devices and communications networks including hardware software and data that are used in the operation of the power system

Critical Cyber Assets Those Cyber Assets essential to the reliable operation of CriticalAssets

Critical Assets Facilities systems and equipment which if destroyed damaged or degraded or otherwise rendered unavailable would have a significant impact on the ability to serve large quantities of customers for an extended period of time would have a detrimental impact on the reliability or operability of the Bulk Electric System or would cause significant risk to public health and safety

AssetsCyberAssetsCritical

Assets

CriticalCyberAssets

copy Cyber SECurity Consulting - All rights reserved

G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

copy Cyber SECurity Consulting - All rights reserved

ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

copy Cyber SECurity Consulting - All rights reserved

Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

copy Cyber SECurity Consulting - All rights reserved

Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

copy Cyber SECurity Consulting - All rights reserved

Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

copy Cyber SECurity Consulting - All rights reserved

CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

copy Cyber SECurity Consulting - All rights reserved

CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

copy Cyber SECurity Consulting - All rights reserved

CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

copy Cyber SECurity Consulting - All rights reserved

ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

copy Cyber SECurity Consulting - All rights reserved

Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

copy Cyber SECurity Consulting - All rights reserved

CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 9: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

G

G

G

G

G

G

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

Load

DG

DG

Transmission Grid Distribution GridSub-Transmission

Distributedgeneration

Generating Plants

Transmissionsubstation

Transmissionlines

Systeminterconnect

Distributionsubstations

Electrical Grid 101Electrical Grid 101

copy Cyber SECurity Consulting - All rights reserved

ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

copy Cyber SECurity Consulting - All rights reserved

Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

copy Cyber SECurity Consulting - All rights reserved

Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

copy Cyber SECurity Consulting - All rights reserved

Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

copy Cyber SECurity Consulting - All rights reserved

CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 10: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

ECAR mdash East Central Area Reliability Coordination Agreement ERCOT mdash Electric Reliability Council of Texas FRCC mdash Florida Reliability Coordinating Council MAAC mdash Mid-Atlantic Area Council MAIN mdash Mid-America Interconnected Network

MAPP mdash Mid-Continent Area Power Pool NPCC mdash Northeast Power Coordinating Council SERC mdash Southeastern Electric Reliability Council SPP mdash Southwest Power Pool WSCC mdash Western Systems Coordinating Council

Electrical Grid 101 ndash Continental NetworkElectrical Grid 101 ndash Continental Network

Western Interconnect Eastern Interconnect

Texas Interconnect

California ISO

New England ISONew YorkISO

Regional Reliability Councils - NERC

copy Cyber SECurity Consulting - All rights reserved

Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 11: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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Regional AuthorityRegional Authoritybull RTORTObull ISOISObull EMSEMS

Critical Cyber AssetsCritical Cyber Assets

Adjacent Entity EMSAdjacent Entity EMS Adjacent Entity EMSAdjacent Entity EMSSCADAEMSSCADAEMS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS Power Plant DCSPower Plant DCS

Substation ControlsSubstation Controls

Power Plant DCSPower Plant DCS

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 12: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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Critical Assets (Power System)Critical Assets (Power System)

bull Control Centers and backupalternate Control Centers

bull Control Center systems (SCADAEMS) and equipment used for telemetry monitoring amp control AGC power system real-time modeling (state estimation) real-time inter-utility data exchanges (ICCP links)

bull Transmission substation equipment supporting an interconnection Reliability Operating Limit (IROL)

bull Generating plantsresources that meet or exceed 80 of the largest single contingency within an operating region

bull Generation control centers with total generation that meets or exceeds 80 of the largest single contingency within an operating region

bull Systems equipment and facilities needed for system restoration including black-start capabilities and substations on transmission lines needed for initial system restoration

bull Systems equipment and facilities needed for automated load shedding on systems capable of shedding 300 MW or more load

bull Any other assets that if damaged degraded or made unavailable would impact the reliability of the electric grid and bulk electric system

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 13: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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Potential Critical Cyber Assets Potential Critical Cyber Assets

bull Computer systems (SCADAEMS DCS DA etc)

bull Servers

bull Communications equipment

bull Substation IEDs automation equipment

bull Remote Terminal Units (RTUs)

bull Workstations amp Operator Consoles

bull Engineering PCs

bull Communication circuits

bull Routers switches and gateways

bull RDBMS

bull Historians

bull Computer-devices that use ldquoroutablerdquo protocols (IP-based) on a network that

extends outside of a substation control center or generating plant

bull Computer-devices that support remote telephone LAN or Internet access

bull Wireless LAN equipment

bull Files databases software backup media documentation manuals etc

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

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2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 14: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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CIP 00x

Compliance Schedule for Most Entities

Compliance Schedule ndash GeneralizedCompliance Schedule ndash Generalized

R1R2R3R4

Rx

Begin WorkBegin WorkSubstantial CompletionSubstantial CompletionCompletionCompletionAuditable ComplianceAuditable Compliance

diams

diams

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

diamsdiamsdiamsdiams

TodayEach CIP is composed of a set of requirements

Most requirements must achieve AC by

end of 2010

Some requirements must achieve AC by end of 2009

CIP 001 is in place for all utilities 002-009are the main effort now

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 15: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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CIP-001 Sabotage ReportingCIP-001 Sabotage Reporting

Required Initial Actions

Create employee awareness of the need to monitor for and formally report any attempt to sabotage facilities or assets and to contact responsible entities (such as the FBI) and provide written reporting using NERC-issued forms and formats Establish formal contacts at the FBI and maintain audit records

Required On-Going Actions

Establish a policy and procedures that insure that employees know their responsibilities and the mechanisms for reporting in a timely manner

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 16: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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CIP-002 Critical Cyber AssetsCIP-002 Critical Cyber Assets

Required Initial Actions

Create an inventory of Critical power system Assets and then using a risk assessment methodology identify the associated Critical Cyber Assets that are essential for the proper operation and availability of those Critical Assets Assign responsibility for overseeing this activity to a senior manager

bull R1 ndash Define a risk-based methodology for critical asset identificationbull R1 ndash Identify and inventory critical electric system assets bull R2 ndash Identify and inventory critical cyber assets bull R3 ndash Perform annual (and as-needed) reviews of these inventories

Required On-Going Actions

Establish a policy and procedures that insure that these inventories are reviewed and updated at least annually and within 90 days of whenever a Critical Asset is added removed from service or operationally modified Audit trail documentation should be maintained for at least one year

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ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 17: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

ThreatVulnerability AssessmentThreatVulnerability Assessment

Normally the ldquoriskrdquo assessment process includes a vulnerability and threat assessment component These are used to identify and rate threats and attack modalities in alignment with identified vulnerabilities

NERCFERC have essentially stated that there are credible and probable threat agents and that the risk of a physical andor cyber (electronic) attack is sufficiently probable enough to justify the countermeasures mandated in the CIPs

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 18: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

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Public Health and Safety

Customer outages

Outage duration

Power system stability

Power generation

impacts

Very serious consequences

Numerous Deaths and

serious injuries

250000 gt customers

Duration in terms of months

Major transmission line outages

gt10000 Mw put offline

Major consequences

Scattered deaths or serious injuries

100000 gt customers

Duration in terms of weeks

Limited inter-tie disruption

gt1000 Mw put offline

Minor consequences

Minor non-life threatening

injuries

Thousands of customers

Duration in terms of days

Temporary islanding

gt100 Mw put offline

Insignificant consequences

None of significance

Hundreds of customers

Duration in terms of hours

No impact Tolerable generation

outage

Risk-Based AssessmentsRisk-Based Assessments

Category of consequences of an attack

Sev

erity

of

cons

eque

nces

Example of a possible consequence rating chart

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CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

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Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

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Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

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2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 19: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-003 Security Management ControlsCIP-003 Security Management Controls

Required Initial Actions

Create an overarching security management program with associated policies guidelines baselines and procedures that will insure the on-going attention to and priority of security as a corporate objective and requirement

bull R1 ndash Develop document and implement a cyber security policy covering at the minimum the eight CIP standards bull R2 ndash Assign a senior manager to be responsible and accountablebull R3 ndash Document and justify all exceptions to the policybull R4 ndash Establish information protection policies and proceduresbull R5 ndash Implement policies and procedures for information access controlsbull R6 ndash Implement a change-management procedure for all critical cyber assets

Required On-Going Actions

Establish a policy and procedures that insure that employees are aware of and adhering to the stated policies and procedures and insure that an annual review is made of the compliance exceptions and of the efficacy of the policies and procedures Audit trail information should be retained for at least one year

copy Cyber SECurity Consulting - All rights reserved

Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

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Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

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CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

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CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

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FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

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Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

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CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

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Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

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FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

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FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

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FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 20: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Security PoliciesSecurity Policies

Security PolicyInformation Security PoliciesOrganizational SecurityInformation Security InfrastructureSecurity Of Third-Party AccessOutsourcing

AssetInformation Classification And ControlAccountability For AssetInformation ClassificationInformation access procedures

PersonnelBackground checksHiring and termination proceduresNDA requirementsJob rotationseparation of dutiesSecurity In Job Definition And ResourcingUser TrainingResponding To Security Incidents And Malfunctions

Physical And Environmental SecuritySecure Areas (security perimeter)Equipment SecurityGeneral ControlsMonitoring and auditing

Communications And Operations ManagementOperational Procedures And ResponsibilitiesSystem Planning And AcceptanceProtection Against Malicious SoftwareHousekeepingMedia Handling and SecurityExchanges Of Information And Software

PhysicalElectronic Access ControlBusiness Requirement For Access ControlUser Access ManagementUser ResponsibilitiesNetwork Access ControlOperating System Access ControlApplication Access ControlMonitoring System Access And UseMobile Computing

Auditing and Review Policy

Systems Development And MaintenanceSecurity Requirements Of SystemsSecurity In Application SystemsCryptographic ControlsSecurity Of System FilesSecurity In Development And Support Processes

Operational Continuity ManagementIncident reportingresponseRecovery planning and testing

ComplianceCompliance With Legal Requirements (SOXHIPPA)Compliance with NERC 12001300Reviews Of Security Policy And Technical ComplianceSystem Audit Considerations

High-Level Information Security PolicyDetailed Information Security PolicyTelecommuting and Portable ComputerPDACell phone Security PolicyManagement IssuesAccess ControlBackup And Media StorageCommunications LinksCommunications LinksSystem ManagementTravel ConsiderationsPhysical Security

External Communications Security PolicyPersonal Computer Security PolicyDocument OverviewBusiness Use OnlyConfiguration ControlAccess ControlVirusesBackupDestructionDocumentationNetworkingPhysical SecurityManagement

Electronic Mail PolicyIM PolicyWeb Browsing Policy

copy Cyber SECurity Consulting - All rights reserved

Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

copy Cyber SECurity Consulting - All rights reserved

CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

copy Cyber SECurity Consulting - All rights reserved

CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

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Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

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Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

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Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

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CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

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CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 21: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Security Policies Security Policies (Cont)(Cont)

Computer Network Security PolicyPurposeScopeGeneral PolicyResponsibilitiesSystem Access ControlEnd-User PasswordsPassword System Set-UpLogon and Logoff ProcessSystem PrivilegesEstablishment Of Access PathsComputer Viruses Worms And Trojan HorsesData And Program BackupEncryptionPortable ComputersRemote PrintingPrivacyLogs And Other Systems Security ToolsHandling Network Security InformationPatch management and installationPhysical Security Of Computer And Communications GearExceptions and violations

Internet Security Policy For UsersIntroductionInformation IntegrityInformation ConfidentialityPublic RepresentationsIntellectual Property RightsAccess ControlPersonal UsePrivacy ExpectationsReporting Security Problems

Privacy Policy - StringentOverview And ApplicabilityDefinitionsSpecific RequirementsInformation To Be Given To The IndividualIndividuals Right Of Access To DataIndividuals Right To ObjectDisclosure Of Personal Data To Third PartiesProcessing Confidentiality And SecurityMonitoring Of Internal Activities

Privacy Policy - Lenient Company Intentions and Management ResponsibilitiesDisclosure Of Private InformationAppropriate Handling of Private InformationPrivate Information on Computer and Communication SystemActivity Monitoring (computer phone FAX)Handling Personnel InformationPrivate Information from Job SeekersPrivate Information About Customers Vendors

Web Privacy Policy

Data Classification PolicyAccess ControlClassification LabelsLabelingThird-Party InteractionsShipping And HandlingDeclassification And DowngradingDestruction And DisposalPhysical SecuritySpecial Considerations For Secret Information

External Party Information Disclosure Policy Determining If Disclosure Is AppropriateResolving Problems With Disclosure ProcessesRequired Disclosure RecordsPreparing Information For Disclosure

Information Ownership Policy

Firewall PolicyDownload Policy

Security Awareness-Raising MethodsIn PersonIn WritingOn SystemsOn Other Things

External Network Interface Security Policy HarmonizationAccess Control ConsiderationsEncryption And Public Key Infrastructure ConsiderationsChange Control And Contingency Planning ConsiderationsNetwork Management Considerations

copy Cyber SECurity Consulting - All rights reserved

CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

copy Cyber SECurity Consulting - All rights reserved

CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

copy Cyber SECurity Consulting - All rights reserved

SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 22: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-004 Personnel amp TrainingCIP-004 Personnel amp Training

Required Initial Actions

Create a program with policies and procedures and routine audit and verification to insure personnel have job-appropriate access rights cyber security training and are suitable for the positions of trust assigned to them

bull R1 ndash Implement a security awareness program to focus all personnel on security issuesbull R2 ndash Establish detailed cyber security training including procedural and policy training for all personnel with physical and electronic access rightsbull R3 ndash Perform background criminal and financial checks on all personnel with physical and electronic access rightsbull R4 ndash Identify and document the personnel needing access rights and relate access rights to job requirements

Required On-Going Actions

Establish a program of on-going security awareness and HR procedures that initially and periodically (re)qualify personnel that are to have secure access Review and adjust access rights as personnel status and job descriptions change

copy Cyber SECurity Consulting - All rights reserved

CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

copy Cyber SECurity Consulting - All rights reserved

SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

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Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 23: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-005 Electronic SecurityCIP-005 Electronic Security

Required Initial Actions

Identify and document the full range of electronic access points that provide an interface into critical cyber assets the account management of all computer assets and perform a vulnerability assessment to identify potential weaknesses and threats to cyber security

bull R1 ndash Identify the electronic security perimeter and all access pointsbull R2 ndash Establish electronic access controls with strong authenticationbull R3 ndash Monitor and review all electronic access to critical systemsbull R4 ndash Perform a cyber vulnerability assessment that identifies and addresses all electronic perimeter access points tests for open ports and services and improper account management bull R5 ndash Classify protect and establish policies and procedures in regards to the information and documentation resulting from this process

Required On-Going Actions

Establish a program and procedures that protect the resulting documentation and insures that vulnerability assessments are performed and evaluated on a periodic basis and that appropriate countermeasures are deployed as needed

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Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

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Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 24: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Electronic Security Perimeter The logical border surrounding a network to which Critical Cyber

Assets are connected and for which access is controlled

The issue here is to identify The issue here is to identify ALLALL communication interfaces communication interfaces - Telephone [leaseddialcellular] - Telephone [leaseddialcellular] - LAN WAN WLAN - LAN WAN WLAN - Privatepublic Networks - Privatepublic Networks - ldquoSNEAKERnetrdquo (portable devicesmedia) - ldquoSNEAKERnetrdquo (portable devicesmedia) - Other - Other

If they provide access to your critical cyber assets then insure that they are If they provide access to your critical cyber assets then insure that they are actually requiredactually required and if so and if so properly protectedproperly protected using suitable technological using suitable technological countermeasures Included in this requirement is a need for effective electronic countermeasures Included in this requirement is a need for effective electronic authentication authentication and for and for access monitoringaccess monitoring and and intrusion detectionintrusion detection

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SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

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CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 25: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

SCADAEMS SystemFacility

LAN

GatewayGatewayWeb serverWeb server

EmailEmail

TelCo

INTERNETINTERNET

TelCo

WAN

A relatedsystem

UnprotectedMODEM

The Electronic PerimeterThe Electronic Perimeter

ISP

Dial-outbackup

RTUsRTUs

x

x

x x

x

x xPhysicalmedia

WiFiWiFiAPAP

Doubly-connectedworkstations

x

xPortable devices

x

Storagedevices

x

DeptLAN

Corporate

SCADALAN

Backup siteSCADAEMS System

TransmissionSubstations

TelCo

Leased T1 lineLeased T1 line

IP t

o t

he s

ub

stati

on

IP t

o t

he s

ub

stati

on

TelCo

Dial-inIED access

x

x

x

x

Establishing the ldquoElectronic PerimeterrdquoEstablishing the ldquoElectronic Perimeterrdquo

Regional balancing authority

Transmission Operator or Reliability

Coordinator

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 26: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoElectronic PerimeterrdquoDefending the ldquoElectronic Perimeterrdquo

Intrusion Detection (NIDSHIDS) Systems

Strong (multi-factor) authentication

Encryption on portable mediadevices

VPNEncryption on communication circuits

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 27: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-006 Physical Security of Critical Cyber AssetsCIP-006 Physical Security of Critical Cyber Assets

Required Initial Actions

Create a program to insure that physical access to cyber assets is restricted to authorized personnel that personnel authentication is adequate that access is recorded and that attempts at unauthorized access are detected and foiled

bull R1 ndash Establish the physical security plan and perimeter that contains all of the critical cyber assets and identify all access points into that perimeterbull R2 ndash Establish physical access controls at all access pointsbull R3 ndash Monitor access into the security perimeter in a manner that precludes undetected access bull R4 ndash Log and record all access into the security perimeterbull R5 - Retain a log of all access attempts either successful or unauthorizedbull R6 ndash Establish procedures and a program to periodically test all access controls and monitoring methodologies and record a log of outages

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 28: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Physical Security of Critical Cyber Assets Physical Security of Critical Cyber Assets (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures that insure that physical access rights are correctly assigned and reviewed whenever personnel status and job requirements change Maintain adequate access control measures and monitoring as well as an auditable log for all of this and periodically verify the proper function of access controls and monitoring mechanisms

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 29: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Important Terms Important Terms (cont)(cont)

Physical Security Perimeter The physical six-wall border surrounding computer rooms telecommunication rooms operation centers and other locations in

which Critical Cyber Assets are housed and for which access is controlled

The issue here is to identity the The issue here is to identity the physical locationphysical location of all critical cyber assets (and of all critical cyber assets (and their support infrastructure) and insure that physical their support infrastructure) and insure that physical access restrictionsaccess restrictions and and controlscontrols are provided to keep them inaccessible to unauthorized personnel are provided to keep them inaccessible to unauthorized personnel Included in this requirement is the implementation of suitable ldquostrongrdquo Included in this requirement is the implementation of suitable ldquostrongrdquo identificationauthentication technologies and use of 247 identificationauthentication technologies and use of 247 access monitoringaccess monitoring and and access loggingaccess logging at all perimeter access points at all perimeter access points

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 30: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FacilityFacility

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

SCADA OperationsSCADA Operations

Limited monitoredcontrolled access pointsLimited monitoredcontrolled access points

ControlledControlledMonitoredMonitored

AccessAccess

Control RoomControl Room

Computerserver RoomComputerserver Room

Office AreasOffice Areas TelecomLAN RoomTelecomLAN Room

Monitored hallwaysMonitored hallways

SeparateSeparateAccessAccessRightsRights

Establishing the ldquoPhysical PerimeterrdquoEstablishing the ldquoPhysical Perimeterrdquo

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 31: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Defending the ldquoPhysical PerimeterrdquoDefending the ldquoPhysical Perimeterrdquo

Visual monitoring using cameras and recorders

Access control systems with alarms and sensors

Walls doors cages barriers and locks

Guards at entryexit points and patrolling

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 32: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-007 Systems Security ManagementCIP-007 Systems Security Management

Required Initial Actions

Create a system security management program that establishes and enforces good cyberIT procedures and policies in the use of addition to and modification of critical cyber assets and systems

bull R1 ndash Establish suitable testing procedures for all new systems and major system changes and upgradesbull R2 ndash Disable unnecessary TCPUDP ports and OS services on all critical systems and implement other measures where this is not possible bull R3 ndash Establish a patch management program and procedures to track and install security patches into critical cyber systems in an operationally safe mannerbull R4 ndash Establish an anti-virus management program and procedures to perform malware scanning and detection on a periodic basis and to update virus detection software on critical cyber systems in an operationally safe manner

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 33: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Systems Security Management Systems Security Management (Cont)(Cont)

Required On-Going Actions

Establish a program and procedures to insure that the requirements listed are regularly reviewed and renewed as required to maintain adequate security

Required Initial Actions (cont)

bull R5 ndash Establish an account management program and procedures to insure ldquostrongrdquo user authentication proper assignment of user rights based on need and tracking of user activitiesbull R6 ndash Put in place monitoring technologies that track electronic access attempts into the security perimeter and provide automatic notification of security violation attempts (NIDSHIDS)bull R7 ndash Establish policies and procedures for retirement and disposal of critical cyber assets and audit trails for such assetsbull R8 ndash Perform cyber vulnerability assessments on a periodic basis and use the resulting findings to guide countermeasure deployment and remediation effortsbull R9 ndash Establish a document management review and revision program that insures that documentation remains accurate and updated

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 34: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-008 Incident Reporting amp Response PlanningCIP-008 Incident Reporting amp Response Planning

Required Initial Actions

Create policies and procedures that guide personnel through the process of reporting documenting responding to and recovering from cyber incidents and insure that all applicable personnel are regularly trained on these procedures and that procedures are validated and modified as required

bull R1 ndash Establish and document a security incident response plan that insures compliance with the NERC IAW program and that guides personnel through the process of reporting and response including defining responsibilities and incident categorizationbull R2 ndash Document incidents and captureretain applicable collateral documentation that supports incident investigation

Required On-Going Actions

Establish policies and procedures that insure the validity and effectiveness of procedures and amends them as needed and that enforces the regular rehearsal of critical procedures by applicable personnel

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 35: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

CIP-009 Recovery Plans for Critical Cyber AssetsCIP-009 Recovery Plans for Critical Cyber Assets

Required Initial Actions

Create a program to develop and test written procedures and training programs bull R1 ndash Create document validate and train personnel on recovery procedures for critical cyber assets and systemsbull R2 ndash Schedule and execute periodic drills on the procedures in an operationally appropriate mannerbull R3 ndash Update and re-validate procedures whenever changes are made to them and insure proper communication of such changes to personnelbull R4 ndash Establish procedures and processes for making and securing backup images of critical systems and information assets and create a cache of all materials tools and other items needed to successfully restore critical cyber assets to full operationbull R5 ndash Periodically perform a test of the backup media to verify it is still usable and suitable for backup operations

Required On-Going Actions

Establish a program to regularly review adjust and update policies and also practice the procedures to insure recovery can be achieved

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 36: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Self Assessment ProcessNERC Self Assessment Process

Identify and Identify and document Critical document Critical

Cyber AssetsCyber Assets

Identify and Identify and document Critical document Critical Cyber Information Cyber Information

Identify and Identify and document Physical document Physical Security Perimeter Security Perimeter

Identify and Identify and document document

communication and communication and network connections network connections

Identify and Identify and document all document all

personnel who have personnel who have access rights access rights

Identify and review Identify and review all existing cyber all existing cyber

security policies and security policies and proceduresprocedures

Information gathering phaseInformation gathering phase

PhysicalPhysicalAuditAudit

PhysicalPhysicalAuditAudit

PhysicalPhysicalInspectionInspection

PhysicalPhysicalInspectionInspection

BackgroundBackgroundcheckschecks

NERCNERCchecklistchecklist

Review findings Review findings versus NERC versus NERC requirements requirements

Develop action plan Develop action plan for addressing all for addressing all

short-comingsshort-comings

Non-Non-compliance compliance

levelslevels

Action plan formulation phaseAction plan formulation phaseKey methodologystandardKey methodologystandard

NERCNERC12001200

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 37: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Cyber Securing SCADA SystemsCyber Securing SCADA Systems

NERC Compliance ProcessNERC Compliance ProcessDevelop and Develop and

document document necessary policies necessary policies

and proceduresand procedures

Select methods for Select methods for creating electronic creating electronic security perimeter security perimeter

Implement and Implement and test the electronic test the electronic

perimeter perimeter

Select methods for Select methods for creating the physical creating the physical security perimeter security perimeter

Implement and test Implement and test the physical security the physical security

perimeter perimeter

Provide security Provide security training to all training to all

employees as neededemployees as needed

Plan implementation phasePlan implementation phase

Iterative Iterative reviewsreviews

Technology Technology surveysurvey

PEN PEN testingtesting

Technology Technology surveysurvey

Social Social engineering engineering

testingtesting

Awareness Awareness campaigncampaign

Test and validate Test and validate Systems Systems

Management and Management and recovery procedures recovery procedures

Test and validate Test and validate systemcomponent systemcomponent testcommissioningtestcommissioning

proceduresprocedures

Disaster Disaster Simulation Simulation

amp auditsamp audits

Key methodologystandardKey methodologystandard

Structured Structured auditaudit

Testing and validation phaseTesting and validation phase

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 38: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FERCrsquos position on the NERC FERCrsquos position on the NERC

Critical Infrastructure Protection Critical Infrastructure Protection

(CIP-002 through CIP-009) Standards(CIP-002 through CIP-009) Standards

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 39: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Recent FERC News UpdatesRecent FERC News Updates

August 1 2007 mdash The Federal Energy Regulatory Commission (FERC) recently proposed to approve a set of reliability standards to help safeguard the nations bulk electric power supply system against potential disruptions from cyber attacks The North American Electric Reliability Corporation (NERC) developed the proposed reliability standards (CIPs) and submitted them to the Commission for approval on August 28 2006 In December 2006 Commission staff issued a preliminary analysis of the cyber security reliability standards and allowed for public comment In the July 19 2007 Notice of Proposed Rulemaking (NOPR) the Commission proposes to approve the eight cyber security reliability standards

The NOPR also calls for NERC to develop modifications to address specific concerns identified by the Commission

As of the beginning of 2008 FERC had issued a mandate requiring the compliance with the NERC CIPs although NERC was asked to continue work on the identified issues

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 40: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC specifically seeks comment on its proposal to direct NERC to provide additional guidance as to the features and functionality of the methodology to be used in identifying critical cyber assets Currently there is little guidance in the standard

FERC rejects language in the CIP reliability standards referring to ldquoreasonable business judgmentrdquo FERC finds that it is unreasonable in the context of implementing sect 215 of the Federal Power Act to allow each user owner or operator to determine compliance with the CIP reliability standards based on its own ldquobusiness standardsrdquo

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 41: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FERC Comments on NERC CIPsFERC Comments on NERC CIPs

FERC also proposes to approve NERCrsquos implementation plan which includes a four-stage schedule for implementing the proposed CIP reliability standards over a three year period According to the implementation plan entities must ldquobegin workrdquo on compliance upon registration with NERC must be ldquosubstantially compliantrdquo within 12 months of registration and must be ldquocompliantrdquo within 24 months of registration Entities must ultimately be ldquoauditably compliantrdquo by 2009 for certain requirements and by 2010 for the remaining requirements

For the interim period before an entity achieves ldquoauditably compliantrdquo status FERC proposes that NERC develop a self-certification process to assess the status of compliance and if necessary assist entities in achieving full compliance in a timely manner

Further FERC proposes to direct NERC to add a cyber security assessment to NERCrsquos existing readiness review process

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 42: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Discretion and Business Judgment

All eight of the standards begin with the statement that the Responsible Entity should interpret and apply the standard using ldquoreasonable business judgmentrdquo This language allows for a broad interpretation of each standard which will result in varying levels of cyber critical asset identification implementation measurement auditing and compliance of the standards The CIP Standards give a Responsible Entity too much latitude in deciding how secure they need to be In addition CIP-002 states that this standard requires the identification of Critical Cyber Assets through a ldquorisk-based assessment methodologyrdquo FERC argued that this first standard is the key to achieving a successful framework and affects the implementation of the remaining standards However with no real guidance given and leaving the identification methodology up to the individual Responsible Entity the result of asset identification will vary significantly with each Responsible Entity

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 43: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Defining Compliance

FERC stated that ldquothe most critical element of a Cyber SecurityStandard is the Requirementsrdquo because they will define what a Responsible Entity must do to be compliant and establish an enforceable obligation However all of the CIP Standards allow too much flexibility and discretion in identifying ldquoexceptionsrdquo or areas where the Responsible Entity can document instances where they cannot conform to the cyber security policy FERC has stated that the auditable compliance timetable extends too far

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 44: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

FERC Concerns with CIPsFERC Concerns with CIPs

1048707 Applicability

Based on the language in the CIPs some entities may interpret that they are too small to be included in these standards Other entities may interpret that they are excluded If the mission of NERC is to ensure the reliability and security of the nationrsquos electric grid all entities small or large must be included and categorized as a Responsible Entity FERCs assessment is that it is not the size of an entity that is critical but rather the potential for an entity to become a vector of vulnerability to the security posture of interconnected controlsystems

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 45: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Control Centers)(Control Centers)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 46: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Balancing Authority Transmission Operators amp Reliability CoordinatorsRequired to self-certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 1 Compliance Schedule ndash Table 1 (Other Facilities)(Other Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diamsdiams

diams

diamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiams

diams

BWBWSCSCCCACAC

diams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 47: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Transmission Service Providers Regional Reliability Organizations and TSPs TOPs and BAs NOT required to Self-Certify compliance to the prior 1200 Urgent Action Standard

Compliance Schedule ndash Table 2 Compliance Schedule ndash Table 2 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

diamsdiamsdiamsdiams

diams

diamsdiams

diams

diams

diamsdiams

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 48: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

2007 2008 2009 2010Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities (IAs TOs etc) required to register during 2006

Compliance Schedule ndash Table 3 Compliance Schedule ndash Table 3 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diamsdiamsdiams

diams

diams

diamsdiams

diams

diams

diams

diams

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 49: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Registration Plus

Q1 Q2 Q3 Q4 Q5 Q6 Q3 Q7 Q8 Q9 Q10 Q11

CIP 002

CIP 003

CIP 004

CIP 005

CIP 006

Compliance Schedule for Responsible Entities Registering in 2007 and Thereafter

Compliance Schedule ndash Table 4 Compliance Schedule ndash Table 4 (All Facilities)(All Facilities)

R1R2R3R4

R1R2R3R4R5R6

R1R2R3R4

R1R2R3R4R5

R1R2R3R4R5R6

CIP 007

R1R2R3R4R5R6R7R8R9

R1R2

R1R2R3R4R5

CIP 009

CIP 008

BWBWSCSCCCACAC

diams

diamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiamsdiams

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions

Page 50: © Cyber SECurity Consulting - All rights reserved  Understanding the NERC Critical Infrastructure Protection (CIP-002 through

copy Cyber SECurity Consulting - All rights reserved

Understanding the NERC CIP StandardsUnderstanding the NERC CIP Standards

William T Shaw PhD CISSPPresident ndash Cyber SECurity ConsultingCyber SECurity Consulting

Questions Questions