In June,
after watching the CIP v7 Standards Drafting Team complete work on what I
thought was an excellent approach to rewriting the definition of Low impact
External Routable Connectivity (LERC), I wrote an exuberant post
describing the SDT’s approach, and why I thought it was such an important
development. So you can probably understand why I was chagrined when I read
recently that this approach had been soundly rejected by the NERC ballot body,
and the SDT will probably have to start over again on this important task.
Last week, I
attended the NERC CIPC meeting in Albuquerque, where LERC was an important
topic of conversation, both officially at the meeting and in private
conversations I had with a couple very knowledgeable CIP compliance
professionals. These conversations have made me understand more clearly what
were the main issues that caused the rejection.[i] And I
think I know the best way for the SDT to address that rejection in their new
draft of the LERC definition. Here’s some background which will hopefully
support my proposal:
- The current definition of LERC – developed with the CIP v6
standards - is “Direct user-initiated interactive access or a direct
device-to-device connection to a low impact BES Cyber System(s) from a
Cyber Asset outside the asset containing those low impact BES Cyber
System(s) via a bi-directional routable protocol connection.”
- There was a lot of controversy
in 2015 regarding the meaning of External Routable Connectivity (ERC) for
Medium and High impact BES Cyber Systems. While this controversy was
specifically about ERC, it applied just as much to LERC (although NERC
entities were much more focused on ERC in 2015, since the compliance date
for Highs and Mediums was less than a year away). In fact, most of the
controversy revolved around the meaning of the words “layer 7 application
layer break” in Reference Model 6 (page 36) of the Guidelines and
Technical Basis for CIP-003-6 (even though this technically applied to
LERC, not ERC). This phrase was used by some entities to justify denying
that some Medium impact BES Cyber Systems had ERC; they simply stated that
an intermediate device like a protocol converter or an RTU would “break”
ERC because it imposed a layer 7 break. Many observers – especially at
NERC and FERC – thought this idea was being inappropriately used in cases
where the intermediate device really didn’t break ERC at all. For example,
since a protocol converter merely converts a routable data stream to a
non-routable (serial) stream, it seemed to these observers that ERC wasn’t
being “broken” at all, at least in this case.
- FERC didn’t have any standing to intervene in the ERC
dispute; they had approved the ERC definition along with the rest of CIP
v5 and hadn’t ordered any changes. However, I’m guessing that they feared
the same controversy would arise regarding Low impact assets as NERC
entities started implementing CIP-003-6 Attachment 1 Section 3.1 (where
the LERC definition applies); so they decided to clarify the issue by
mandating a change in the LERC definition.[ii]
- FERC approved CIP v6 – including the LERC definition – in
January 2016, in Order
822. But they also directed (paragraphs 65-75) that NERC revise the
LERC definition. Specifically, they seized on the word “Direct” and ordered
that NERC clarify the meaning of that word to reflect the commentary in
the Guidelines and Technical Basis. It seems to me that FERC thought that
the controversy over the meaning of “layer 7 application layer break”
could be resolved if NERC made it clear under exactly what circumstances
there was direct communication and under what circumstances there wasn’t
direct communication. Once that was clear, there would be no dispute over
whether a particular intermediate device “breaks” LERC or not – all that
would need to be done was to determine (using the clarified meaning of
“direct”) whether there was direct communications or not. If the
communications continued to be direct, the device clearly didn’t break
LERC; if it was no longer direct, then the device did break LERC. In my
post on Order 822 (second-to-last paragraph), I expressed skepticism that
this approach would work, since I didn’t see any good way to define a “layer
7 break” without invoking some concept like “direct”, leading to a
circular argument. As it is, my point became moot when the SDT decided to
change not only the LERC definition, but the requirement itself.
- As I just said, the SDT didn’t simply redefine LERC (which
now stands for Low impact External Routable Communications). They also modified the “requirement part”
where LERC was applied (CIP-003-6 Attachment 1 Section 3.1) to make it
non-prescriptive. You can see the whole account of what they did in the
post referenced at the top of this post. The principal change was that
they defined LERC as external routable connectivity that crossed the
“asset boundary” of the asset; as long as there is any routable traffic
across that boundary, there is LERC. In other words, a device that imposes
a layer 7 protocol break won’t actually break LERC itself.
- At first, this might seem like an outrageous change. What
was the SDT doing, thinking they could take away everything that breaks
LERC? Why, using the new definition, even data diodes won’t break it! I
know some people thought this way, but this was simply because they
weren’t looking at everything the SDT had done. True, the SDT took away
everything that “broke” LERC, but they also changed the requirement that
LERC applies to (CIP-006-3 Attachment 1, Section 3.1). It currently reads “For LERC, if any,
implement a LEAP to permit only necessary inbound and outbound
bi-directional routable protocol access.” They changed it to read
“Implement electronic access control(s) for LERC, if any, to permit only
necessary electronic access to low impact BES Cyber System(s).”
- Of course, this is now a non-prescriptive requirement. It
no longer says you have to implement a LEAP (Low impact Electronic Access
Point) whenever there is LERC.[iii]
It simply says you have to take steps to mitigate the risk posed by LERC.
And what steps can you take? The Guidance and Technical Basis now lists a
number of those steps (in a new set of “Reference Model” diagrams), but
the SDT makes clear other steps are possible as well (and it is possible
that some ways of implementing the steps in the diagrams may not fully mitigate the risk posed
by LERC; the auditor will have to determine whether this happens, in each
case). The possible steps that mitigate the risk posed by LERC now include
the different measures that used to “break” LERC, including network
separation and data diodes. These were both able to break LERC because the
LERC definition implicitly allowed for that possibility. If there is
network separation and the BCS are on a network that doesn’t communicate
with the outside world, there obviously can be no “direct” communications
from the outside, so the LERC definition no longer applies. By the same
token, a data diode will eliminate “bi-directional” routable communication,
so the LERC definition no longer applies in that case, either. It would
have been helpful if the v6 SDT had made these two provisions explicit,
rather than implicit. On the other hand, there are a lot of cases - at
least 40 or 50 - of other v5 and v6 requirements being implicit in the
wording of the standards. It would be nice to see all of those made explicit, but I doubt that will happen.
- Besides these two measures now being included in the set
of suggested LERC mitigations included in the Guidance and Technical
Basis, those mitigations also include a number of measures that used to be
subsumed in the idea of the “Layer 7 application layer break”. These
include requiring re-authentication of the user, terminating the
communications and starting a new one, and requiring network- or
host-based inbound and outbound access permission. So the SDT solved the
ambiguity of “Layer 7 application layer break” by eliminating the term,
and listing specific steps in the Guidance that might be sufficient to
mitigate the risk posed by LERC.
- The bottom line is that, in spite of the changes the SDT
made, all of the steps that used to legitimately “break” LERC – and
therefore remove the requirement to implement a LEAP – have been
re-christened as mitigations to the risk posed by LERC. If you take one of
these steps, you will still not need to implement a firewall, although
firewalls and similar devices (which used to be called LEAPs) are also
listed as possible mitigations. The only steps that would no longer be
valid ones would be those that depended on a device – like the protocol
converter discussed above - that was claimed to “break” the routable
protocol, but which didn’t perform one of the other steps listed above,
such as re-authentication or terminating one session and starting a new
one (which is what a terminal server often does). And frankly, I believe
FERC was aiming at precisely this result when they ordered NERC to rewrite
the LERC definition. I really think the SDT hit the nail on the head in
their first draft on this issue, which makes its overwhelming rejection disappointing
to me.
- All of this has been to say that I don’t believe the
objection that the SDT had “taken away” the steps that “break” LERC in the
first draft were valid. Those steps (network separation and data diodes, devices
that require re-authentication or start a new session, and network or
host-based access permissions) are still valid measures to take, but they
are defined as mitigating the risk of LERC rather than breaking it
altogether. The end result, however, is exactly the same – an entity that
deploys one of these measures will most likely have sufficiently mitigated
the risk posed by inbound routable communications that they will not be in
violation of the requirement. The idea that the SDT “took away” data
diodes and network separation as ways to comply with the requirement
regarding LERC is mistaken.
- But this now leads us to the more serious objection to
what the SDT did: The SDT “defined” LERC as always being present when a
routable connection crosses the asset boundary.[iv]
A lot of entities were concerned that they are now going to have to
declare LERC at a Low impact asset, even if there are not any OT cyber
assets connected to it. And you know what? This is exactly the case.[v]
- But what are the consequences of this? Let’s look at the
case where there is a routable external connection to a network of IT
cyber assets (email server, work order server, some personal workstations,
etc) at a Low impact asset; there are also some BCS that are on their own
network without an external routable connection at all. Yes, there is
LERC, according to the new definition. But the entity merely needs to
point out that the risk posed by LERC is mitigated by the network
separation; I find it very hard to believe that this statement will not be
accepted, unless the auditor has reason to believe there is in fact a
connection between the two networks. In other words, the new LERC
definition (and the revised requirement for mitigating the risk posed by
LERC) will at most impose a small paperwork burden on the entity; it will
not require any additional compliance steps.[vi]
- However, some might say, “Why should we even impose this
small burden? Let’s go back to the old way, where LERC could be broken by
various means like network separation, and you didn’t have to do anything
more if that were the case?” And the answer is, because FERC (and NERC, to
be honest. See their Memorandum on this issue from April 2015 – except you
can’t see it online, since it has been withdrawn) is very concerned about
the word “direct” being misinterpreted to allow the possibility of pure
protocol converters (as well as similar devices) being considered as
breaking the “direct” connection. We simply can’t leave the definition as
it is in CIP v6.
- On the other hand, I don’t think politically the SDT can
simply take their first draft on this issue and resubmit it as the second
draft, even with more of an education campaign and some beefed up Guidance
to show people that they were wrong in voting down the first draft. While
I would like to think everybody’s minds might be changed by this, I
realize the SDT has to make some changes in the next draft.
So here are
my suggestions for the next SDT draft on the LERC issue:
- Go back to the idea of LERC being an external routable
connection to a BCS at a Low impact asset (meaning the “asset boundary”
wording goes away) that can be “broken” in various ways. However, all of
the items that break LERC need to be explicit, not implicit in the
definition. In other words, there should be a statement saying that LERC
is not present if
- No Low BCS is routably connected to this
external routable communications (i.e. network separation); or
- The routable communications is not
bi-directional (i.e. there is a data diode in place).
- There should also be a provision in the definition dealing
with the issue with smartphones, discussed in footnote vi below.
- Of course, the word “direct” needs to stay out of the
definition, since the legitimate applications of that word
(re-authentication and new session) are now included as possible
mitigations for LERC, and since the “illegitimate” applications of the
word – for devices like protocol converters – are no longer allowed as
mitigations by themselves.
- Leave the revised requirement (which is found in paragraph
3.1 of Attachment 1 of CIP-003-7) as it stands from the first draft.
- Remove from the set of Reference Models in the Guidance
and Technical Basis the two models that deal with network separation and
data diodes (since these are once again included in the definition as things
that can break LERC, although that inclusion will now be explicit, not
implicit).
I think the approach I’ve just described
meets the primary objections to the first draft fairly well, with only a small
loss in elegance in the LERC definition. When I started writing this post, I
was thinking there would be a more serious consequence of doing this –
requiring an inventory of all Low BCS – but now I realize that isn’t the case.
All in all, it isn’t a bad solution, and I hope the SDT will seriously consider
it at their meeting in Winnipeg, Manitoba this week (which I cannot attend).
One other note to the SDT: This whole episode
shows the danger of being too fascinated with the idea of elegance in wording
(and I admit I was fascinated with that idea too, as my original post shows),
especially when it involves a fairly radical shift from the wording people are
already used to.
The views and opinions expressed here are my own and don’t
necessarily represent the views or opinions of Deloitte Advisory.
[i]
I will be the first to admit that I haven’t actually read the voluminous comments
that were submitted to NERC on the LERC issue. But the official discussion by
Dave Revill of the SDT meshed very well with the private comments I heard,
which leads me to believe I understand the two main objections.
[ii]
I am going even further to guess that FERC realized that whatever new
definition NERC came up with for LERC would end up applying to ERC as well,
since it would be hard to have two different definitions for what is
essentially the same thing. We’ll see if that happens or not; I know the SDT is
discussing changes to the ERC definition, but they have to deal with LERC first
because FERC set a deadline of early 2018 to get them the revised definition.
[iii]
In fact, the SDT eliminated the definition of LEAP, since a firewall or similar
device is now only one of many ways to mitigate the risks posed by the presence
of LERC.
[iv]
There was another objection that I haven’t discussed here, which is also a valid
one: there were no mandatory criteria determining how to draw the asset
boundary. This caused more than one entity to worry that an auditor would issue
them a PV because his or her idea of the asset boundary didn’t correspond with
the entity’s idea. While the SDT deliberately avoided saying the boundary has
to be the fence line, the line around the building, etc, there was one
criterion they discussed in the meeting I attended in June that didn’t make it
into the guidelines: the asset boundary has to encompass all BES Cyber Systems
at the asset. If the SDT had put this in the Guidance, I think it would have
given an entity a good idea whether or not their definition of the boundary was
valid and defensible.
[v]
There is a related objection, which is that in a Low asset that is shared by
multiple entities, if one entity has a routable external connection to BCS that
it owns, the other entity will have to declare LERC, even though its own BCS
don’t participate in that connection. This is certainly true. However, it will
not impose any great regulatory burden on the other entity, who will simply
point to the network separation as sufficient mitigation of the risk imposed by
LERC at the asset. I will point out that there are a bunch of serious issues with CIP v5 and v6, caused by the
fact that the standards currently take no official cognizance of the fact that
there can be assets shared by multiple NERC entities. For several months, I
have been promising a few people (and it seems that Florida is Ground Zero for
this problem, since I’ve heard more about this issue from FRCC than any other
region) that I will address this in a post. I still intend to do that, although
I simply haven’t been able to take the time to research the different issues
that make up the problem.
[vi]
At the CIPC meeting, I heard another objection which sounds more serious: Since
almost every smartphone is able to communicate routably, and that routable
connectivity won’t usually end when its owner crosses the asset boundary of a
Low impact asset, it is possible the entity would have to declare LERC many
times every day, literally when almost anybody, employee or not, walks into the
asset. Of course, the entity would simply have to declare in every case that
the smartphone wasn’t communicating with any Low impact BCS in order to show
that the LERC risk was mitigated; but it would be a royal pain to have to do
this so often. I do think this is a serious objection, but it could easily be
dealt with by putting some wording in the LERC definition that eliminated this
possibility. I do agree that entities shouldn’t have to deal with this, since
all of these instances would add up to a huge paperwork burden, in spite of the
fact that there would be no further compliance obligation.
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