I attended
WECC’s CIPUG – CIP User Group – in Anaheim, Calif. last week. This was the third CIPUG I’ve attended in
this location, at a hotel a couple blocks from the gates of Disneyland. It was as usual an intimate gathering – just
me and 350 of my closest friends. And as
usual, it was a very well-organized and well-programmed event.
The first
time I heard about a CIPUG being next to Disneyland, I thought, “How
appropriate. There is such a huge amount
of unreality in NERC CIP; we’ll all feel right at home there.” But after attending the meeting last week, I
saw this juxtaposition from an almost opposite perspective.
I have often
put myself in the place of the people working in Disneyland, and especially
Fantasyland – playing Mickey and Minnie Mouse, the Seven Dwarfs, etc. I am sure these people have no illusions
that they work in a make-believe world.
When they come off work, they don’t have to adjust to our “real” world –they
feel they never left it. The only people
who actually believe in the make-believe world of Fantasyland are of course the
very young kids who visit there.
Let’s
contrast this with the people attending the CIPUG: staff members of NERC, WECC,
and the NERC Responsible Entities, as well as consultants like me. We are all indulging in fantasies about NERC
CIP Version 5 and its path to implementation; those fantasies were on display
in the CIPUG presentations as well as the conversations at breakfast, lunch and
the breaks. The difference between us
and the people who play the Fantasyland characters is that they know they’re in
a make-believe world. Those of us
attending the CIPUG, on the other hand, didn’t have a clue that this is the
case. We were in the position of the young kids visiting Fantasyland, not the
workers putting in their time there and thinking about anything except Mickey
Mouse.
In this
post, I will list three fantasies that are quite prevalent in the world of NERC
CIP and that were on display at the CIPUG (but, of course, that are certainly
not limited to the people who attended the CIPUG). I do wish to point out that I am not singling
out any particular individuals as being more prone to these fantasies than
anyone else, although I will illustrate the fantasies through their
manifestation in the presentations and discussions at the CIPUG. These are institutional
fantasies that have evolved to enable the whole NERC CIP “world” to live with
an increasingly impossible situation, and to justify the fact that thousands of
people in that world are plodding dutifully ahead, with no clear idea where
they’re actually going or whether in fact they are really getting anywhere at
all.[i]
Note: The
CIPUG was just one of a total of three days of meetings. The first two days were a combination of the
WECC Compliance User Group (or CUG - i.e. the group that manages compliance
with the other NERC and WECC standards, collectively known as the “693” or “O
& P” standards) and the Western Interconnect Compliance Forum (WICF) – the
association of NERC compliance professionals at WECC entities (whose meetings
and forums are off-limits to NERC and WECC staff members). The presentations from the entire three days can
be found at this
location; you can find the ones relevant to CIP by looking for titles with
“CIP” or “Cyber Security”.[ii]
Fantasy Number One: The Foundation of CIP
Version 5 is Strong
It’s no
surprise when I tell you that NERC and WECC (and the other seven Regional
Entities) are moving forward (perhaps not at full
speed) on implementing CIP Version 5.
Given that, it should also be no surprise that the NERC and WECC staff
members, in their presentations, didn’t bring up any fundamental issues with v5.
They certainly did mention various issues that needed to be resolved,
but none of the “hold the presses” variety.
Indeed, how could they stay in their current jobs unless they truly
believed this? NERC is committed to
implementing CIP v5 as written; if you don’t think that can really be done, you
should seek employment elsewhere.
If you’ve
read any of my posts since April 2013, you know that I think the foundation of
CIP v5 is rotten. The foundation consists
primarily of CIP-002-5.1. I recently documented
twenty serious problems with that standard, and I’m sure I could add another 15
– 20 problems to that today without much effort (some of these came out
directly or inadvertently in the CIPUG presentations).
But the
“foundations” of CIP v5 aren’t just in CIP-002; they’re part of other standards
as well, especially CIP-005-5. And this
is why I found the presentation
by Morgan King of WECC on CIP-005 Lessons Learned to be so interesting. Morgan did a very good job of discussing four
Lessons Learned (none finalized as of yet, and one or two not even released in
draft form) that relate to CIP-005. His
presentation provides some good information, although I really wish there were
recordings available, since the Q&A was the really interesting part.
The
Q&A for Morgan’s presentation clearly revealed something I’d already
suspected: as you[iii]
start to probe more deeply into any particular question about CIP v5, you’re
almost certain to uncover a number of additional questions. And so it went with Morgan. He addressed four particular Lessons Learned,
but I’d say there were 3 - 5 new questions raised about each one (and if there
weren’t five questions raised, it’s only because discussion had to be shut off
to move to the next presentation. There
could have easily been at least a whole half day of Q&A just on Morgan’s
presentation; this is true for a few of the other presentations as well,
especially those of Dr. Joe Baugh on CIP
v5 Pilot Study Lessons Learned and Lisa Wood on Low
Impact Assets[iv]
in v5. I highly recommend WECC expand
the CIPUG to a day and a half, just like the CUG).
I
unfortunately didn’t take notes on the different issues that were raised – they
came fast and furious, and as I said Morgan (as well as all of the presenters)
was under a lot of pressure to finish up so the next presentation could
start. I do remember there were a lot
of questions on the External Routable Connectivity discussion at the beginning
of the presentation and the Virtualization discussion at the end. Morgan handled these new questions in the
only way he could be expected to: by saying the NERC Transition Advisory Group
(of which he’s an active member) hadn’t addressed them yet.[v]
To
illustrate what I said about new questions being raised as soon as you try to
address one question in CIP v5, I’ll point you to page 18 in Morgan’s
presentation. There, he lists three
criteria for the presence of External Routable Connectivity, including “Would
the misuse or disruption of those routable protocols or BES Cyber Assets have
an adverse impact on the BES within 15 minutes?” This isn’t a question that was asked at the
meeting, but I’ll ask it now: What does adverse BES impact – within 15 minutes
or 15 years – have to do with the question whether a cyber asset has ERC? Adverse BES impact is certainly important for
determining whether a Cyber Asset meets the BES Cyber Asset definition (as I
discussed in this
post), but it has nothing to do with
ERC.
Note (Feb. 2): Morgan emailed me this morning to point out that his slide 18 (the one discussed above) had been unclear; the third bullet point (quoted above) really had to do with the question whether the protocol converter was a BCS (see slide 12), in which case the question about adverse BES impact does make sense. He said he mentioned this during the presentation, which I don't doubt - there was so much he had to say and he (like the other presenters) was rushing through it so quickly that I couldn't really absorb even half of the things he said. Besides extending the CIPUG to a day and a half (it's really about 6 hours now), WECC should also make the webinar recording publicly available (they webcast the CUG/CIPUG for WECC members, who have to pay to "attend" that, just as they do to attend the live event).
And this brings up another topic. In his presentation, Tobias Whitney of NERC said that one way NERC plans to get more information out to entities regarding CIP v5 is the new "CIP University". No, CU won't consist of nice Gothic buildings with ivy on them. It will make CIP meetings hosted by the different regions available to all NERC attendees. This is nice, but it isn't going to make a huge difference, since I don't believe any of the other regions make their meetings available by webcast like WECC does; requiring people to attend in person, with limited travel budgets, isn't going to greatly increase the learning opportunities.
More importantly, what WECC is doing for CIP v5 education is far beyond what any of the other regions have done. WECC has had three two-day v5 workshops, and will be having two workshops on Low impact assets (one is this week, although it's sold out). This is in addition to the three-times-a-year CIPUGs. I don't know any other region that has had more than 2-3 days worth of CIP v5 workshops so far (a couple have had zero that I know of); this isn't surprising, since WECC is far more than twice the size of any other region. I have always recommended that people from other regions attend WECC meetings. This is allowed (although I don't know if the webinars are made available to non-WECC entities), and is encouraged because there really isn't a lot of WECC-specific content in the meetings (there was virtually none in the CIPUG); everyone can benefit from them. Maybe WECC can offer to expand their meetings and make them all available to NERC entities online.
Note (Feb. 2): Morgan emailed me this morning to point out that his slide 18 (the one discussed above) had been unclear; the third bullet point (quoted above) really had to do with the question whether the protocol converter was a BCS (see slide 12), in which case the question about adverse BES impact does make sense. He said he mentioned this during the presentation, which I don't doubt - there was so much he had to say and he (like the other presenters) was rushing through it so quickly that I couldn't really absorb even half of the things he said. Besides extending the CIPUG to a day and a half (it's really about 6 hours now), WECC should also make the webinar recording publicly available (they webcast the CUG/CIPUG for WECC members, who have to pay to "attend" that, just as they do to attend the live event).
And this brings up another topic. In his presentation, Tobias Whitney of NERC said that one way NERC plans to get more information out to entities regarding CIP v5 is the new "CIP University". No, CU won't consist of nice Gothic buildings with ivy on them. It will make CIP meetings hosted by the different regions available to all NERC attendees. This is nice, but it isn't going to make a huge difference, since I don't believe any of the other regions make their meetings available by webcast like WECC does; requiring people to attend in person, with limited travel budgets, isn't going to greatly increase the learning opportunities.
More importantly, what WECC is doing for CIP v5 education is far beyond what any of the other regions have done. WECC has had three two-day v5 workshops, and will be having two workshops on Low impact assets (one is this week, although it's sold out). This is in addition to the three-times-a-year CIPUGs. I don't know any other region that has had more than 2-3 days worth of CIP v5 workshops so far (a couple have had zero that I know of); this isn't surprising, since WECC is far more than twice the size of any other region. I have always recommended that people from other regions attend WECC meetings. This is allowed (although I don't know if the webinars are made available to non-WECC entities), and is encouraged because there really isn't a lot of WECC-specific content in the meetings (there was virtually none in the CIPUG); everyone can benefit from them. Maybe WECC can offer to expand their meetings and make them all available to NERC entities online.
Another
issue I had with Morgan’s presentation was at the end, when he said – probably
as part of his response to a question – that a network switch would be a BES
Cyber Asset. I recently wrote a post
pointing out that another NERC auditor (different region) strongly believes
switches should not be BCAs. I won’t say
who is right on this matter (although I lean toward the other auditor’s position). However, this shows there are some
fundamental questions that are being seriously debated now (or should be
debated, if they’re not) within NERC – exactly 14 months before the High/Medium
compliance date. Anybody else see a
problem with this?
Speaking of
getting on to the next topic, it’s time for me to get on to the next fantasy
that was revealed at the CIPUG. Suffice
it to say that the primary “lesson learned” I took away from Morgan’s
presentation (as well as a couple others) was that there can be no end to the
questions raised about CIP v5, at least within a finite time period such as,
say, the 14 months between now and April 1, 2016.
Fantasy Number Two: The Interpretation
Issues with CIP v5 are Manageable
The previous
paragraph is a great lead-in to this fantasy.
I state again that I’m not pointing a finger at any particular
individuals as subject to the fantasies discussed in this post, but I will use
the presentation by Tobias Whitney of NERC – and his response to a question I
asked him in the meeting – as an illustration of this fantasy.
Tobias’
presentation was titled “Version
5 Pilot, RAI Initiative and Transition Guidance”. It was good, and especially important because
he –as the person in charge of all of this – was the one delivering it. A highlight was his list of 15 (or so)
Lessons Learned that he promised would be addressed by April 1 of this year. He also mentioned that entities should submit
any new questions to their regions, who will then submit them to NERC.
My question
to Tobias was in essence the following, but it was much shorter: “Tobias, it’s
wonderful that you’re addressing 15 questions by April 1. By the way, you didn’t mention that you’re
using FAQs to address some other questions, but you have addressed maybe 30 additional
questions that way, and will undoubtedly do more FAQs as well. However , as we saw in the presentations
earlier today – especially Morgan’s – the questions keep metastasizing, so that
as you probe deeper into almost any one of them you find a number of
further questions, and so on perhaps ad
infinitum.[vi] I’m sure that NERC entities could today come
up collectively with over 500 serious questions on CIP v5, with more appearing
all the time.
“I’m not
asking you to tell me when every v5 question will be addressed. You obviously can’t tell me that until you
have a list of all v5 questions. But since
these questions are clearly growing daily, what can NERC do to at least develop
and maintain a comprehensive online list of v5 questions that have been asked
to date? These would be questions that
don’t have an easy answer by referring to the wording of the standards, or one
of the guidance documents like the Lessons Learned (although those have to be answered as well). I think this list would provide a big benefit
just by itself, even though it wouldn’t actually answer any questions. Even though NERC entities wouldn’t have
answers to most of these questions, they would at least have a rough idea of the size
of the elephant as they take bites out of it.”
Tobias’ answer
to me was quite interesting, and not at all what I expected. He didn’t dispute the idea that there were
many questions on v5 that NERC hasn’t even thought of yet, or that NERC
ultimately will struggle to address every question that comes up[vii]. What he said was that a comprehensive list of
questions might be a bad idea because it could cause entities to get
discouraged and slow down or even stop their current efforts to come into v5
compliance! When I expressed my surprise
at this answer, he backed away from it, but later seemed to come back to it
when he mentioned the danger of “paralysis by analysis”.
Think of
what this means. He seems to be saying
NERC entities need to at some point simply charge ahead and do their best to
come into compliance with v5, even though they may have all sorts of questions (both
officially acknowledged and unacknowledged questions, as well as ones that are
unknown at the moment) that could call into question whether portions of their
effort are actually in error and need to be re-done or simply abandoned.[viii]
This might
be good advice for adventurers heading off to explore new territory. For them, it’s obviously impossible to know
in advance all the obstacles that may lie ahead (otherwise, it wouldn’t be new territory). But it doesn’t exactly strike me as wonderful
advice for organizations that are moving to comply with a new set of standards,
where there can potentially be huge fines for non-compliance. What if Entity A takes his advice, puts aside
any questions they have about whether they’re properly identifying BES Cyber Systems,
and proceeds to develop an entire v5 compliance program based on a set of “BCS”
that, as it turns out, weren’t properly identified in the first place? Is Tobias saying they won’t get assessed a PV
when an auditor – maybe four years from now – realizes they have completely
missed the boat?
Maybe he is saying this. I’ve already said
regarding CIP-002-5.1 R1 that, not only should it be declared an “open” requirement
with no PV’s assessed for good-faith efforts to comply, but that it will be an open requirement even if not
actually “declared” so. This is because
no NERC auditor is going to assess a violation for a requirement that is
ambiguously worded, and which the entity has tried their best to understand and
comply with. Maybe this idea really
applies to all of the CIP v5 standards, not just CIP-002.[ix] In other words, maybe the entire set of v5
standards should be declared open; and even if not declared so, they will be
anyway because the auditors won’t assess PVs.
If Tobias
really means to declare all of the v5 standards to be open ones, he of course
needs to first get NERC and FERC on board with that idea; at the moment I think
that would be quite a challenge. So
maybe his idea is to either postpone the v5 compliance dates (as I advocated in
this
post), or to declare just the first year of compliance to be an “open” one
(which I didn’t advocate, although I’m not against this as long as it’s stated
explicitly by NERC – not just left up to the discretion of the auditors. There’s far too much auditor discretion
already, and nobody is unhappier about that situation than the auditors
themselves. They want clear guidance).[x]
In any case,
it should be clear that I’m not satisfied with Tobias’ answer to me. I certainly agree that entities shouldn’t
stop their CIP v5 compliance efforts at this point. But I don’t see any way they can go ahead
with an untroubled mind – as Tobias wants them to do – without the compliance
date being moved back or the whole of CIP v5 being declared “open” for a year
or so.[xi]
Fantasy No. 3: “We’ve Got it Under Control”
The third
fantasy I identified at the CIPUG (and have identified before) is one indulged
in by some compliance personnel at Registered Entities. They believe they have CIP v5 pretty well
figured out, and just need to fill in the blanks in order to complete their
compliance implementation.
Let me say
that I don’t think these people are lying when they say this. They honestly believe that – while there are
admittedly some less-important questions that need to be resolved – the
fundamental concepts in CIP v5 are clear.
And why shouldn’t they believe that?
Every NERC presentation, webinar, bulletin, etc. says or implies the
same thing. I have yet to see a
presentation by a NERC staff member who says, “Yes, for this important v5 issue
we haven’t a clue about what we’re going to do to address it.” Yet I could name a number of very fundamental
issues[xii] for
which that is exactly the case (or at least NERC hasn't announced they're addressing them).
I quoted the
physicist Richard Feynman in a recent post,
who famously said “If you think you understand quantum mechanics, you don't
understand quantum mechanics.” I’ll
paraphrase that: “If you think you understand how NERC CIP v5 works, you don’t
understand how NERC CIP v5 works.” As
someone who has spent close to two years trying to understand how CIP v5 works
and isn’t much further toward that goal than when I started, I absolutely
believe this to be true. No matter how
smart you are, how many people you’ve talked to, or how many conferences you’ve
attended, if you think you have CIP v5 down pat conceptually and you can just unthinkingly
forge ahead to compliance, you’re living in Fantasyland. The utmost humility is called for when CIP
Version 5 is concerned.
As an
example of this, one consultant and I were discussing at CIPUG the entities who
say they understand CIP v5, then say that they really just have to identify all
of their Critical Cyber Assets from CIP v3 as BES Cyber Systems, and they’ll be
done with their BCS identification (one entity said that to me at the
CIPUG). If you’re one of these, I won’t
say you’re wrong when you think that your lists of BCS (or BCAs) and CCAs will
be the same; you may well be right about this.
However, you are wrong if you
think the auditor will be satisfied if you tell him/her you just took your CCA
list and made it your BCS list.
CIP-002-5.1 R1 requires you to develop and document a methodology for
identifying BES Cyber Systems, and to apply that methodology to identify
BCS. You need to develop the methodology,
and then run every Cyber Asset you have through it to develop your BCS
list. If it turns out the result
identifies the exact same cyber assets that were on your CCA list, great. But you can never assume that at the start.
So this is
the last of the three fantasies I saw running rampant at the WECC CIPUG last
week. Like the measles, these things
seem to spread at Disneyland.
The views and opinions expressed here are my
own and don’t necessarily represent the views or opinions of Honeywell.
Feb. 9: I've written a sequel of sorts to this post, which you can find here.
Feb. 9: I've written a sequel of sorts to this post, which you can find here.
[i]
Of course, institutional fantasies are nothing unique to the NERC world. In fact, there is probably no institution
that doesn’t indulge in its own fantasies, since not to do so would make it
impossible for the employees to do their work.
Examples (and much more serious ones) include:
·
I’m sure employees of tobacco companies – in the
years before the companies finally admitted the documented serious health
effects were in fact real – were trained in how to respond when people brought
up these effects to them: by denying that there were such effects (and probably
believing that what they said was true).
What else could they possibly do?
·
I’m also sure that most US
Congressmen/Congresswomen and Senators don’t believe that the vast majority of
the work they’ve been doing in recent years has been completely futile, if not
outright counterproductive. How can you possibly
stand before the voters and ask to be re-elected, with any other belief in your
mind?
·
There are people to this day that assert that
the Vietnam War produced some positive good for the people of Vietnam. Again, if you were closely involved with that
effort, how could you say otherwise?
[ii]
A few of the CUG presentations will be of interest to CIP compliance
professionals, even if they don’t deal with any other NERC standards. This includes one presentation on the BES
definition and about five on RAI – two with “RAI” in the title, as well as
presentations labeled “Internal Controls” and “Risk-Based Framework”.
[iii]
And by “you” I mean a cyber security professional. I am not that, but there were of course many
of them in the room at the CIPUG.
[iv]
I notice now that Lisa’s presentation is shown as being about “Low Impact BES
Cyber Systems” on the WECC page, but the actual title on the slides says “Low
Impact Assets”. Of course, the politically
correct way to say this is “Assets Containing a Low Impact BCS” (and Lisa did
catch herself and use that phrase a few times), which is a nonsensical attempt
to bridge the gap between the two completely different points of view from
which CIP-002-5.1 was written (without any clear reconciliation). I’ve written about this sorry mess a number
of times, including in this
post under the heading “Have an Apple, Adam?”
[v]
I much prefer Morgan’s approach to answering hard questions to that of a NERC
manager who often addresses industry meetings, and who seems to feel compelled
to answer every question that gets raised.
This has led him multiple times to say things that later have to be
retracted or reworded by NERC. Unless
you’re going to say that the opinions you’re expressing are entirely your own
(as I do in this blog), you shouldn’t be making statements without confirming
them with the organization under whose auspices you’re making those statements.
[vi]
I have wondered why the situation is so much different with CIP v5 than it was
with v1-v3, where there were certainly some questions but they seemed to be
much fewer, and much more contained. I
believe the problem is that v5 was much more ambitious, and requires the entity
to make judgments about a number of areas that weren’t relevant in CIP
v1-3. The bright-line criteria are one
example of this, but the biggest example is probably the concepts of BES Cyber
Asset and BES Cyber System. Just look at
my recent post
on “methodology” for BCS identification and classification to see how
fiendishly complicated – and ill-defined – the concepts of BCA and BCS really
are. I hope to have a post on this topic
in the future.
[vii]
In fact, I will state unequivocally that there is no way NERC will ever be able to address all of the questions
with v5, no matter what time frame you look at.
[viii]
In fact, there is a real danger that some entities’ CIP v5 compliance efforts
may be entirely for naught if it turns out they guessed the answer to a
particular question wrong. Let’s say
your entity has only one Medium impact substation, and that the Attachment 1
criterion it falls under is ambiguous.
You go ahead and spend a million or so (which isn’t a lot for a large
entity’s compliance program, but is huge for a small entity’s) implementing
compliance with all the requirements, for that substation. Four years later, you get audited and the
auditor casually mentions, “Oh, that criterion was recently clarified by
(someone at NERC), and your substation would now be considered Low impact.” Wouldn’t that make you feel wonderful?
[ix]
Of course, by CIP v5 I really mean the combination of v5, v6 and v7 standards
that entities will actually have to comply with, which I have otherwise called CIP
v6.3940.
[x]
Even if CIP v5 is declared “open” for a year or so (I’m sure the idea of making
it permanently open wouldn’t fly with FERC or Congress), NERC also needs to
write a Standards Authorization Request for a complete rewrite of
CIP-002-5.1. While the other CIP v5
standards can probably be salvaged with enough interpretation effort, CIP-002
is beyond salvation. It needs to be
condemned to the eternal fires and be reborn in a completely new standard. That
will take a few years, but at the end CIP v5 will be on a solid
foundation. Without that, there will
always be questions about whether an entity has properly identified and
classified its BES Cyber Systems in the first place, even if there are no
remaining questions about the other v5 standards. I called for rewriting CIP-002 in this
post.
[xi]
At one point in his presentation, Tobias asked how many entities had completed
their CIP v5 compliance implementation. He
seemed genuinely surprised when nobody – of the 350 people in the room – raised
their hand. I would have been astounded
if anyone had.
[xii]
Here are five examples of fundamental issues that NERC doesn’t even plan to
resolve, as far as I know: a) the use of Facilities
vs. assets in the bright-line criteria; b) the meaning of “impact
the BES”; c) the status of the term “Group of Facilities” (discussed in the
CIP-002 Guidance) as it relates to the Criteria; d) whether connectivity has
anything to do with whether a Cyber Asset is a BCA; and e) whether entities are
advised to group BCAs into different BCSs depending on the requirement (this is
implied to be desirable in the Lessons Learned document on “Grouping
BES Cyber Assets”, but strikes me – and others – as a recipe for utter
chaos). These are all quite fundamental
questions that NERC hasn’t even said they’ll produce guidance on (I intend to
do posts on all of them, not just the first two, which I have already
addressed). I could definitely list a
few more, except I’ve already been working on this post all day (fortunately,
there’s a huge blizzard going on in Chicago as I write this, and I don’t feel
bad that I’m not doing something outside the house).
I'll take the BLUE pill, please.
ReplyDeleteExcellent analysis, as always, Tom. You continue to shed light on and bring discussion to important issues facing us all.
I've got to find my way out of the trenches and partipate in one of these events and engage the broader community.
In the meantime - back to Fantasy Island (err... I mean, FantasyLand). Those Mickey Mouse ears are around here SOMEwhere...
Cheers!
Billy
As we develop our CIP v5+ Training Suite we are constantly amazed at the volume of instances where subjectivity is the basis for compliance.
ReplyDeleteConsider the words “or similar” in the definition for “Exceptional Circumstance”. Subjective criteria requires the entity to develop their own list of what they consider to be exceptional circumstances AND develop AND document the reason(s) they believe each circumstance identified meets the inferred criteria in the glossary definition.
CIP 008 requires an entity to report incidents they have identified as reportable within the timeframes specified for those incident types. Nowhere is there specified within the standard a minimum OR maximum acceptable timeframe for determining whether an incident meets the criteria of reportable. So who becomes – in the words of George Bush - the “decider”? The individual auditor will have free rein unless the entity once again develops a clear process and supportable timeframe for this task.
The flexibility of subjectivity is fine for “guidelines” or “best practices” – but STANDARDS implies a need to comply with an “established criteria”. How does one comply with “or similar”?
As unaccustomed as I am to defending the wording of the CIP v5 standards, I think you may be overthinking these two issues, Quizzicle.
ReplyDeleteThe definition of "CIP Exceptional Circumstance" gives the entity the ability to identify more potential exceptional circumstance types than the ones explicitly provided in the definition. It seems reasonable to me that they should have to document - after an exceptional circumstance has been resolved - why this particular circumstance was similar to one of the types listed in the definition. If they abuse this privilege by creating spurious types of exceptional circumstance - e.g. "deer hunting season" - I can see why they might be subject to a PV. But the alternative - spelling out a host of potential exceptional circumstances and not allowing the entity to identify others - strikes me as being more burdensome, not less. If there is reasonable doubt whether or not a type of circumstance is "similar" or not, I would hope there would be no PV assessed - and if there were, I would hope the entity would fight it. But there will always be gray areas in any standard; I'm not saying they can be eliminated.
Regarding the 008 issue, are you suggesting there also be a requirement that the entity, in the event of a cyber security incident, decide during a set period of time (10 minutes?) whether an event is reportable? Would that really help anybody? I think entities should decide as soon as possible whether an incident is reportable, keeping in mind that if it is reportable, they need to do report it within an hour. I don't think they need a further requirement, and I don't think an auditor will accuse them of not deciding quickly enough, unless they took much longer than an hour to even decide whether the incident was reportable in the first place. Again, there's always going to be some gray in every standard, but trying to eliminate that completely quickly leads to a much larger regulatory burden - that then introduces further regulatory risk.