Interpretation and Definition Issues in CIP-002-5.1 R1 and Attachment 1

This is the second of a series of four posts on the serious problems with CIP-002-5.1 R1, and what NERC entities and NERC need to do to address them.  The first post is here.  The next post is here.

In the at least 30 posts I have done on problems with CIP-002-5.1 R1 and Attachment 1 (hereinafter “R1”), I have identified many problems with the wording in that document.  However, I’ve never gathered these together in one post.  I am now doing that, both for the sake of clarity and to support a couple new posts I’ll be doing very soon.

This list is important because NERC entities with Medium and High impact assets need to get started very quickly – if they haven’t already – on developing their final lists of cyber assets in scope for CIP v5, and they can’t do that without having some resolution to the issues listed below[i].  Unfortunately, none of these issues have been finally resolved – that can only done by rewriting R1, or by capital I Interpretations, which take 2-3 years.

Please note:

• This is far from being a complete list of problems with R1.  For one thing, there are a whole host of issues with the bright-line criteria, since those criteria don’t seem to fit any asset very well.  I’m sure you could easily more than double this list by including all of those issues.  And I’m sure there are more problems in the other parts of R1 as well.
• All of the issues in this list relate to Medium impact Transmission substations, since it is for these assets that the bulk of the CIP v5 effort will be expended.  There are other issues that relate to control centers, generating stations, etc. that I haven’t included in this list; I hope to add those at a later date.  On the other hand, all entities subject to CIP v5 compliance should find this list useful.  Most of the items on this list apply to all types of BES assets, not just substations.
• I have addressed some of these issues in previous posts; I include links in those cases.  I hope to do future posts on some of the other issues.
• FWIW, NERC has included a couple of these issues on their list of planned Lessons Learned and FAQs.  If we’re lucky we’ll see a draft for comment of these documents within a few months.  But my guess is there aren’t too many entities that will feel comfortable waiting a few more months to identify their cyber assets in scope for v5, while the compliance date remains 4/1/16.  If you’re still waiting to do this, you’ve already waited too long.  You need to get moving, even though that means taking these issues into your own hands to resolve.
• My suggestion is that, for each of the issues below, entities should decide how they will interpret each one (in conversation with their NERC Regional Entity, if possible) and document it – then go about identifying their cyber assets in scope.  Of course, any guidance NERC has provided will be helpful, as will any advice from the Regional Entity.  But remember, the only mandatory “guidance” is the wording of the standards themselves, along with any capital “I” Interpretations that NERC and FERC may approve.  The standards aren’t going to change in the next few years, and there will be no Interpretations available for at least 2-3 years.  I don’t advise anyone to wait for either of these things to happen, before they start to become compliant with CIP v5.

Here’s the list:

1.       The beginning of Section 4.2 of CIP-002-5.1 says “…the following Facilities, systems, and equipment owned by each Responsible Entity in 4.1 above are those to which these requirements are applicable…”  Yet R1 talks about “BES Cyber Systems” as being in scope and also discusses six types of “assets”.  Attachment 1 discusses things like “control center”, “generation”, “reactive resources”, “Transmission Facilities”, SPS, RAS, and “system or group of Elements”.  What is the relation, if any, between all of these things and “Facilities, systems and equipment” in 4.2?  And if there is no real relation, why is this wording in 4.2?

I can see that “Facilities” might be taken to roughly correspond to the “big iron” referenced in the bright-line criteria (i.e. roughly “assets” and true “Facilities”).  I can also see that “systems” might refer to the BES Cyber Systems that will be in scope for v5.  But “equipment”?  That sounds more like monkey wrenches and forklift trucks.  Is that really in scope for v5?  Does the entity need to come up with a list of all the “equipment” they own and decide what impact it has on the BES?  I’m sure they don’t, but that would be a valid interpretation of this section.

2.       Subsection 4.2.2 seems to narrow “Facilities, systems and equipment” down by saying that, for all entities listed in 4.1 except DP’s, what is in scope for them is “All BES Facilities”.  If the SDT hadn’t capitalized “Facilities”, this would be quite easy to understand, since lower case “facility” can generally be thought to be any of the “big iron” to which CIP v5 might apply, including control centers, substations, generating stations, etc.  However, the fact that Facility is capitalized means it’s a NERC defined term.  If you look it up in the NERC Glossary (and also look up Element, which is a key part of the Facility definition), you’ll see that a Facility has to have terminals and presumably be operated at high voltage.  Do you know any control centers that have terminals and are operated at high voltage?  I don’t either.  This means that all control centers are out of scope for CIP v5!  I’m sure all the big BA’s will be pleased to hear this.[ii]

3.       There’s another “get out of jail free” card embedded in the quote from Section 4.2 in item 1 above.  Note that the “Facilities, systems and equipment” need to be “owned by” the Responsible Entity, in order for them to be in scope for CIP v5.  So to eliminate your CIP compliance burden, how about selling your equipment – or even the asset itself – and leasing it back?  Businesses do this all the time as a financial strategy.  There you go: You don’t own anything, so you don’t have anything in scope for v5!

4.       Of course, the whole point of R1 is to identify and classify BES Cyber Systems.  What is the first step in that process?  If you restrict yourself to the wording of the requirement itself, the only thing you have to go by is R1.1 – R1.3, since they constitute the entire actionable part of the requirement.  1.1 and 1.2 tell you to respectively “Identify each of the high impact BES Cyber Systems….” and “Identify each of the medium impact BES Cyber Systems…”  But how do you do that?  There is nothing in the requirement to guide you, other than the definitions themselves.  And you have to work backwards.  Since you’re told BCS are your target, you need to read the BCS definition first; of course, that references BCAs, so you then need to read that definition; that references Cyber Assets, so now you need to read that definition. 

Why couldn’t these three crucial steps have been each explicitly stated in R1?  Better yet, why couldn’t they have been broken up into three or four separate requirements, as was the case in CIP v1 – v4?  The whole process would have been much easier to understand if this had been done; plus the whole process would have been a lot less susceptible to confusion, as shown below.

5.       The first step for identifying BES Cyber Assets/Systems is to identify Cyber Assets, which are defined as “programmable electronic devices.”  But what does “programmable” mean?  This is on NERC’s list to address, of course, but many entities have decided they can’t wait for NERC to do something to start their BCS identification process.  These entities have developed and documented their own definition (a number of entities – especially owners of large generating stations – did this last summer.  They had to get going on their v5 compliance process then, if they were going to have a good chance to meet the 4/1/16 compliance date).

6.       The definition of BES Cyber Asset includes the phrase “affect the reliable operation of the BES”.  What does this mean, and how do we measure it?  It’s safe to say that no cyber asset has been installed in a substation, control center or generating station purely because it looks nice.  They can all be said to affect the reliable operation of the BES in some way, albeit small.  So what distinguishes BCAs from other cyber assets?  Again, entities that can’t wait for this issue to be clarified by NERC (and NERC hasn’t even listed this as a topic they’ll address in the Lessons Learned) need to develop and document their own interpretation of this phrase.
6.5    In order to classify a BES Cyber System as Medium or Low impact, you need to know which substation or Facility (see below) it is "associated with", since Section 2 of Attachment 1 says that Medium BCS are those that are associated with any asset/Facility that meets one or more of the Medium criteria.  But "associated with" is not defined, nor does NERC currently plan to define it. Each entity needs to develop its own definition (although EnergySec has developed a white paper that discusses this).  It could be an operational definition, stating for example how to determine which Facility or substation a relay is associated with.

7.       Once you’ve identified your BES Cyber Assets, how do you get to BES Cyber Systems?  The definition of BCS is “One or more BES Cyber Assets logically grouped by a responsible entity to perform one or more reliability tasks for a functional entity.” While the entity has complete discretion on how to do that grouping, some groupings may be more efficient than others, depending on the environment.  Fortunately, NERC does have a good Lessons Learned document on this question; but again, it would have been nice if this step had been explicitly called out, rather than implicitly included – along with about four other steps – in the single word “Identify” in R1.1 and 1.2.  R1’s use of very compressed meanings works very well if you consider it haiku poetry, but not well at all if you consider it a requirement that in theory can carry million-dollar-a-day penalties for violation.

8.       In any case, through applying three NERC definitions (and adding a couple of our own), we have now come up with a list of BES Cyber Systems, staying strictly within R1 itself.  But in the Guidance and Technical Basis section of CIP-002-5.1, there is a lengthy discussion of the BES Reliability Operating Services (aka BROS), including a description of how they can be used to identify BES Cyber Systems; this is what I have called the “top-down approach” to identifying BCS (what we just did above is the “bottom-up” approach). 

However, the BROS are nowhere referenced in R1 (or the BCA/BCS definitions) itself[iii].  What place should they play in identifying BES Cyber Systems, vis-à-vis the “bottom-up” approach described above?  Should an entity use both approaches and then combine the results, in order to make sure they do not over- or under-identify BCS?  This question isn’t raised, let alone answered, in CIP-002-5.1.  Yet it is very important.  If the entity uses just one approach rather than the other, there is a big risk of either under- or over-identifying BES Cyber Systems.  And another consideration: the only approach that’s actually required by R1 is the bottom-up one (although as I’ve just said, that “requirement” is purely implicit in the definitions of three phrases, not overtly stated).

9.       What is the role of the six asset types (control centers, etc) listed in R1?  Are they meant to be the types of assets that are “run through” the bright-line criteria to determine which are High, Medium or Low, or are they the locations at which BCS can be found?  If the former interpretation is chosen, a number of wording conflicts result[iv].  If the latter interpretation is chosen, it needs to be made clear in your R1 compliance methodology that, even though BES Cyber Systems associated with a Medium impact substation can be located outside of the substation itself, they have to be located at one of the six asset types; otherwise, they need to be treated as remote users (I discussed this question in this very long post, under the section Questions of Scope, about 5 or 6 paragraphs down.  Also in this post, in the section entitled “The Auditor’s Methodology”).

10.   Criteria 2.4 – 2.8 apply to Facilities, not assets.  It is clear that substations are not Facilities.  Rather, Facilities are lines, transformers, busses, etc.  Yet the regions seem to differ in their interpretation of “Facilities” in these criteria.  SPP makes clear that Facilities are the lines, etc; NERC also indicates that.  However, some regional auditors (including Joe Baugh of WECC, in his presentation on CIP-002-5.1 in September) have indicated that “Facilities” means “substations” in these criteria.  Which should it be?  If “Facilities” means lines, etc, there will potentially be a lower compliance burden for Transmission entities, since BES Cyber Systems at a “Medium” substation, that are not themselves associated with a Medium Facility (line, etc) will be Low impact.  For instance, at a 500kV substation that falls under criterion 2.4, relays associated with a 230kV line will be Low impact, not Medium.  Only the relays associated with the 500kV line(s) will be Medium impact.

11.   Criteria 2.4 – 2.8 refer to “Transmission Facilities” as being in scope.  This is to distinguish the lines, transformers, etc. that are associated with Transmission from those that are associated with Distribution; this is important, since in many substations both Transmission and Distribution Facilities are present.  However, there are many questions that arise when it comes to actually separating the equipment out.  There needs to be a definition of Transmission Facilities that entities can use to distinguish the two types of Facilities. 

12.   Medium impact BES Cyber Systems are “defined” in Attachment 1 as those that are “associated with” Medium impact Facilities (in criteria 2.4-2.8), meaning they don’t have to be located at the same substation as the line, breaker or transformer they’re associated with.  However, according to NERC’s recent Lessons Learned document, relays that are associated with a Medium impact line - under Criterion 2.5 - through a “transfer-trip” scheme, but which are themselves located at a Low impact substation (i.e. so-called “far-end relays”), are Low impact. Will this exception apply in other cases where systems (like relays) associated with a Medium impact substation or Facility are located at a Low impact substation[v]?

13.   There are a host of issues that come up regarding equipment located in shared substations.  NERC has promised a Lessons Learned document on this question.  Entities that can’t wait for that will have to “roll their own”.

14.   If a relay (or other device) in a substation is connected serially to an intermediate device like a terminal server or RTU, and that intermediate device has External Routable Connectivity, in what circumstances can the relay itself be considered to have ERC?  In what circumstances should it not be considered to have ERC? 

15.   Criteria 2.6 and 2.9 both refer to IROLs, which are not used in WECC.  How should WECC entities interpret these two criteria without referring to IROLs?

16.   What does “routable” mean?  There are about three places in CIP v5 where a definition is required, but there is no NERC definition.  While this may seem like a fairly well-understood term, it isn’t so clear cut when you look at Modbus/TCP, DNP/IP, etc.  NERC’s very well-written 2010 guideline for identifying Critical Cyber Assets (pp. 26-29) contains a good discussion of this issue.  Should entities assume that, if their definition of “routable” coincides with what is discussed in this document, that they are defining it properly?

17.   What constitutes a “substation” (there is no NERC definition)?  This is important for criterion 2.5.  For example, suppose a substation meets the 3000-point threshold in criterion 2.5, but has two separate control rooms.  If each of these control rooms is considered part of a separate substation (say there is a fence between them, or the entity decides to put one there to lower their compliance costs), then each of the separate substations probably won’t have 3000 points.  Instead of one Medium substation, there would be two Low substations, and all the BES Cyber Systems at both “substations” would be Low impact.

18.   Low impact assets are “defined” in R1 as “assets containing a Low impact BCS”.  But no inventory of cyber assets is required for Lows, and thus BCS will never be identified at Low impact assets.  How is this contradiction to be reconciled?   

19.   Conversely, the implication of this “definition” of Low assets seems to be that assets that don’t contain a Low impact BCS aren’t even Lows.  This is good, but how do you prove it to your auditor, without inventorying all the Cyber Assets at the potential Low asset to show that none of them meet the definition of BCA/BCS?

20.   The beginning of Section 3 (“Low Impact Rating”) of Attachment 1 reads: “BES Cyber Systems not included in Sections 1 or 2 above that are associated with any of the following assets…”  This states pretty clearly that the entity is to a) take their pre-existing list of BCS, b) subtract out those BCS not identified as High or Medium impact in Sections 1 or 2, and c) identify the remainder as Low impact BCS.  There is only one problem with this: The entity is never required to make a list of all their BCS before they start to classify them[vi].  In fact, v5 says explicitly in two places that an inventory of Low impact BCS isn’t required.  How can this contradiction be reconciled?

The views and opinions expressed here are my own and don’t necessarily represent the views or opinions of Honeywell.

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[i] The list also contains a couple items – like 14 and 16 – that aren’t really part of R1 per se, but are definitely part of the asset identification process for substations.  Therefore, Transmission entities need to address these at the same time they’re applying R1 to identify BCS.

[ii] Of course, I don’t recommend that Southern California Edison tell WECC that their control centers don’t have to comply with v5; there is too much other evidence in R1 and Attachment 1 that control centers do have to comply.  It was obviously a mistake by the SDT that “Facilities” was capitalized.  I know one region has suggested to NERC that there be an errata filing for all of the v5 standards – since this wording appears in all of them, as well as the v6 and v7 standards – asking to un-capitalize that word in Section 4.2.2.  But I doubt that will happen.

[iii] The BROS were part of the definition of BES Cyber Asset in the first draft of v5, so they were then the “official” means for identifying BCA/BCS; this was changed in the second draft.  See footnote v below.

[iv] For instance, let’s go to the Medium impact criteria in Section 2 of Attachment 1, and see if they “map” to the six asset types.  Each criterion has a subject, generally at the beginning of the criterion.  Some of those subjects do vaguely resemble items on the asset list, but how about criteria 2.2 (where the subject is “reactive resources”), 2.9 (“Each…Remedial Action Scheme (RAS), or automated switching System that operates BES Elements..”), and 2.10 (“automatic load shedding systems”)?  These aren’t on the list of six at all.  Why did the SDT carefully provide us this list of six asset types and tell us to consider them in Attachment 1, then ignore some of them and add some new ones when we actually get to Attachment 1?  The answer is what I’ve just said: the six asset types are the locations where you should look for BES Cyber Systems, not what gets run through the criteria; you classify the BCS themselves using the criteria in Attachment 1.  High BCS will always be located at a High asset, because they have to be “used by and located at” a control center that meets one of the four High criteria.  But Medium BCS don’t have to be located at a Medium asset/Facility, since they just have to be “associated with” the asset/Facility, not “at” it.  It is important to know that a Medium BCS has to be located at one of the six asset types, rather than somewhere else like the home of a manager.

[v] My opinion is they won’t, since NERC’s reasoning for their “ruling” on Transfer-Trip relays was very specifically tied to Criterion 2.5 (and that reasoning had first appeared in this blog post about two months earlier, having been contributed by an Interested Party).

[vi] Actually, in the first draft of CIP v5, which was roundly defeated in the first ballot in December 2011, the wording of R1 clearly required the entity to first inventory all Cyber Assets in its system, whether High, Medium or Low (of course, at this point in the requirement, nothing had yet been classified High, Medium or Low impact).  Then they had to determine which were BCAs (and hence what the BCS were, although the first draft of v5 almost used the terms BCA and BCS interchangeably).  To identify BCAs/BCS, entities had to apply the BES Reliability Operating Services analysis to each cyber asset (since the BCA definition at the time was based on the cyber asset’s fulfilling a BROS).  Of course, this would have been an incredible burden on entities, since it would have literally required spending hours inventorying and classifying every cyber asset they owned.  I wrote a post on this while the first draft was being balloted, and flatter myself that I contributed in a small way to its defeat.  R1 (and the BCA definition) was substantially rewritten at the first SDT meeting after this ballot.