I have been
attending WECC meetings on NERC CIP since 2008 – as many as possible – and have
always found quite important pieces of information in them. I’ve written a
number of posts on what I learned or what went on in these meetings, some
called “The News from WECC” and some with other titles. I’m guessing this might
be the ninth such post, but I’m not sure. In any case, the sheer size of these
meetings (always at least 250 people, usually 350-400), coupled with the size
and talent of the WECC CIP audit staff (9-10 auditors), has always led to some
good discussions and good information.
So it was
with WECC’s “Advanced CIP Training” that I attended in Salt Lake City on
September 9 and 10, 2015. This training had originally been billed as “CIP 101”
(the same title used the previous year), but that was changed in the last
couple of months. It seems we all graduated to Advanced even before we attended
the course! Not having an overall theme for what I’m going to write, I’ll
simply list the different things I learned in roughly the order they were
mentioned in the meetings.
I recommend
that any entity, no matter what region they’re in, take a look at the slides
from this meeting. You can find them here.
I particularly call your attention to the slides (in almost all of the
presentations) showing likely Data Requests and Sample Interview Questions;
these are good for audit preparation, even if you’re not in WECC.
What Breaks External Routable Connectivity?
As discussed
in this
post, FERC made clear in their July NOPR on CIP v6 that they didn’t like NERC’s
idea of what can “break” Low Impact External Routable Connectivity (LERC) at
Low impact assets. Specifically, they said they didn’t like Reference Model 6
in the Guidance and Technical Basis section of CIP-006-6, which stated that
there can be a “protocol break” in conjunction with a change in the
communications stream from routable to serial. As I discussed further in this
post, this argument can well be construed as applying to ERC (i.e. for High and
Medium assets) as well.
In the
meeting, I asked Morgan King, the WECC auditor who had elaborated the idea of a
protocol break in ERC at WECC’s January CIPUG meeting, whether he still thought
that entities could claim this “exemption” – for either Low or Medium/High BES
Cyber Systems. As I expected, he said no – that FERC’s opinion clearly carried
weight for LERC and ERC, even though
it had only been expressed regarding the former.
But even
though FERC didn’t like the general idea of “protocol break”, they didn’t say
there was nothing that could break ERC in the case where the end devices were
serially connected, as is often the case with relays. Morgan agreed with me
that, if a device that “translates” routable to serial communications requires
re-authentication of the user, this still does
break both ERC and LERC. And Morgan did allow for other means of breaking
ERC/LERC as well (this
post lists another situation that I would think fits that bill).[i]
But there’s a Catch to This, in the case of
LERC
When I wrote
about the NOPR, I pointed out “…if the entity is going to prove that there is
no LERC at a particular Low asset – when there is clearly some routable
connection going into the asset – then they are potentially going to have to
identify any BCS and show that there is no LERC to any of them.” I said this
because I saw no way an entity could prove that Cyber Assets at a Low asset
don’t have LERC without being able to demonstrate this for every Cyber Asset.
And this means there needs to be a full inventory of cyber assets at that
asset.
Wanting to
see if WECC saw this the same way, I first asked the question whether WECC will
require an inventory of all Low BCS. The inimitable Dr. Joe Baugh, the WECC
auditor who specializes in asset identification issues, said no. I then asked
Joe whether if an entity were going to claim, for a Low asset that has some
sort of external routable connection, that there is not in fact LERC at that
asset, they would potentially need to be able to show this was the case for
every BCS. He said yes, and admitted that in such a case, the entity will need
to have an inventory of their Low BCS at
that asset. My guess is the other regions would probably say the same thing;
but as in most cases, you need to check with your region if you question this.
LIBCS
This was the
first time I saw this acronym used in the NERC community, but I predict it will
be a big hit. Of course, it means Low Impact BES Cyber System. And Josh Reber
helpfully suggested some even better acronyms on slide 8 of his presentation.
My favorite is MIBESCSWERCATAEACMSAPACS.
CIP-002
You should
do an annual inventory of Cyber Assets for CIP-002 to make sure you haven’t
missed any newly-installed devices. The one exception I would make to this rule
is when an entity has a rock-solid change control process, and they will always
know when a new device has been installed.
CIP-004
In Josh’s
presentation, he mentioned that many entities had wondered what is the typical
number of roles that other entities have delineated for training purposes in
CIP-004-6 R2. He was quite frank: they typically see between 8 and 15 roles.
Now you know.
CIP-005 (Andrews)
Joe Andrews
gave a great presentation
on CIP-005. Some of the points he made:
- He distinguished between “Discreet ESPs”, in which the
entire ESP is contained within one PSP, and “Extended ESPs”, in which an
ESP crosses between rooms or even buildings, and there is some cabling
that goes outside of the PSP. The new CIP-006-6 R1.10 is intended to
address Extended ESPs.
- He pointed out that to separate networks of different
trust levels, you need a Layer 3 device – not a Layer 2 device with VLANs.
- He said network gear needs to be identified as BES Cyber
Assets, since it meets the BCA definition. To be honest, I think there
might be some disagreement on this point, so you should check with your region
if you don’t agree with this.
- He said there can’t be mixed-trust VM environments. So you
can’t have some devices on a VM server that reside in an ESP, and some
that don’t. I believe I heard the opposite on a recent TRE webinar,
but as with all questions on CIP v5, check with your own Regional Entity.
CIP-005 (King)
In case you
have any doubt that some of the thorniest issues in CIP v5 are in CIP-005
(although I’d say it takes second place to CIP-002 in that regard), they will
be allayed when you note that there were actually two presentations on CIP-005
at this event, totaling about 140 slides. The second presentation was by Morgan
King. Two (of many) interesting points in his presentation:
- He pointed out that the NERC Lesson Learned on Interactive
Remote Access provides a good guide to when a remotely-executing script
constitutes IRA and when it doesn’t. See slide 85.
- He noted that an Intermediate System (IS) should be in the
DMZ, but an overriding consideration is that it must be in a PSP; this is
because an IS must be declared an EACMS (per the definition of IS). So if
your DMZ is outside of the PSP, you need to include the IS within the
ESP/PSP.
CIP-007
Eric Weston
and John Graminski did an extensive presentation
on CIP-007-6, which I recommend you read. Some of the interesting points they
made:
- There is such a thing as an “in-line antivirus proxy
device”, which in theory can protect all of the cyber assets within an
ESP. They didn’t say this would eliminate the need for anti-malware
software, but they did point out that it is a good precaution in case
there are devices that don’t have updated A/V signatures.
- For CIP-007 R1.2 compliance (physical ports), it’s not OK
to just put signs warning against use of USB devices on the PSP. They need
to be on the device itself (or its cabinet if locked).
- For R1.1 compliance, a host-based firewall can be used as
evidence that a service is disabled. However, this doesn’t help for
purposes of compliance with CIP-010 R1.1; that is, it doesn’t constitute
evidence that a logical port is not “network accessible”.
- (This point was actually made by one of the participants)
You can’t justify a port just by saying “The vendor requires it.” You need
to point to some reason why it
has to be enabled.
- In R1.4, logging can be performed at either the cyber
asset or the system level (which brings up a good point: Some of the
requirements in CIP-007 can only be performed at the cyber asset level,
e.g., R1 and R2. For these requirements, the words “BES Cyber Systems” in
the Applicability column should be replaced with “Components of BES Cyber
Systems”).
- For R4.2, the Guidance implies that real-time alerting can
be accomplished with technical means only. But the actual requirement
allows for procedural means as well.
There's a follow-on to this post here.
The views and opinions expressed here are my own and don’t necessarily represent the views or opinions of Deloitte Advisory.
The views and opinions expressed here are my own and don’t necessarily represent the views or opinions of Deloitte Advisory.
[i]
I’m told that NERC’s comments on the NOPR introduce a new term: “security
break”. It seems like it’s essentially an authentication break, which I
certainly hope FERC agrees is something that would break LERC (and probably ERC as well).
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