tag:blogger.com,1999:blog-1987420974894463968.post5565421557482786669..comments2024-03-21T03:56:54.312-05:00Comments on Tom Alrich's Blog: No, None of the Other Dates will ChangeTom Alrichhttp://www.blogger.com/profile/11926296316487964077noreply@blogger.comBlogger6125tag:blogger.com,1999:blog-1987420974894463968.post-57634907100239143592016-03-02T10:43:34.837-06:002016-03-02T10:43:34.837-06:00You're right, Ryan. FERC definitely misspoke w...You're right, Ryan. FERC definitely misspoke when they said "High and Medium". Thanks for catching that.Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-18761531974825076992016-03-02T07:41:22.614-06:002016-03-02T07:41:22.614-06:00Since the order simply read: “Accordingly, the imp...Since the order simply read: “Accordingly, the implementation of the CIP version 5 Reliability Standards for entities with High and Medium Impact BES Cyber Systems is deferred from April 1, 2016 to July 1, 2016 to align with the effective date for the revised CIP Reliability Standards approved in Order No. 822.”<br /><br />There are requirements for an audit, as a Low, on 4/1/16. These include an assessment to prove that the entity only has Low Impact BES Cyber Systems (ironic) and a CIP Senior Manager Designation in accordance with CIP-003-5 R3.<br /><br />However, NERC has just yesterday responded with clarification that ALL CIP was pushed back to Version 6 so this point doesn't matter anymore. Ryan Shttps://www.blogger.com/profile/04040026252141803284noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-20297048407726135132016-02-29T11:21:58.849-06:002016-02-29T11:21:58.849-06:00An Interested Party pointed out that I should make...An Interested Party pointed out that I should make it clear that the Initial Performance of Periodic Requirements dates - described in the v5 implementation plan - will also change, since they're tied to the v5 effective date. Since that date is now three months later, they will be three months later as well.Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-9533089110726429382016-02-29T11:20:30.983-06:002016-02-29T11:20:30.983-06:00Ryan, nothing is required on 4/1/16. All the v5 an...Ryan, nothing is required on 4/1/16. All the v5 and v6 standards are now effective on 7/1/16. Highs, Mediums and Lows all have to comply with CIP-002-5.1 R1 on that date, and they need evidence.They also all have to designate their Senior Manager on that date per CIP-003-6 R3.Tom Alrichhttps://www.blogger.com/profile/11926296316487964077noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-16445769732954259272016-02-29T09:25:30.995-06:002016-02-29T09:25:30.995-06:00Not to mention R1 for CIP-002-5.1, which you have ...Not to mention R1 for CIP-002-5.1, which you have to follow to even determine Low/Medium/High. Will Lows be required to have evidence associated w/ this requirement, while Medium/High will not? It doesn't make sense.<br /><br />"Each Responsible Entity shall implement a process that considers each of the<br />following assets for purposes of parts 1.1 through 1.3"Ryan Shttps://www.blogger.com/profile/04040026252141803284noreply@blogger.comtag:blogger.com,1999:blog-1987420974894463968.post-48859945289381235452016-02-29T07:30:36.202-06:002016-02-29T07:30:36.202-06:00It's not entirely meaningless, as documentatio...It's not entirely meaningless, as documentation and designation of CIP Senior Manager will be required under Version 5 on April 1, 2016 for Lows.Ryan Shttps://www.blogger.com/profile/04040026252141803284noreply@blogger.com