Wednesday, November 22, 2023

NERC CIP: The new SAR for cloud services

There is widespread agreement in the NERC CIP community that it’s time – in fact, way past time – to fix the biggest problem with the CIP standards: the fact that, because they’re based on the template established when CIP version 1 was drafted in 2006 and 2007, they unintentionally prevent medium and high impact BES Cyber Systems and EACMS from being installed in the cloud (note that low impact BCS – there are no low EACMS – have always been completely “legal” in the cloud).[i]

It is also important to remember that the current “prohibition” of medium and high impact BCS and EACMS has nothing to do with concerns about the security of cloud service providers, although probably nobody thinks that CSPs should get a “free ride” regarding cybersecurity, even if they have every certification known to man. The prohibition is in place simply because in 2006 when drafting of CIP version 1 began, use of the cloud was still nascent and a “computing system” always consisted of one or more physical devices. There’s no NERC definition of a physical computing device, but my operational definition is that it’s a computing system that, if you drop it on your foot, will hurt. In contrast, if you could even figure out how to pick up and drop a cloud-based system on your foot, it certainly wouldn’t hurt (physicists still don’t think that bits and bytes have mass, although bits are becoming more important in physics all the time).  

Addressing this problem (or more specifically, three problems: BCS in the cloud, EACMS in the cloud, and SaaS in the cloud) requires some major changes to the CIP standards (or perhaps a new standard). Changing the standards requires that a Standards Drafting Team (SDT) be constituted from subject matter experts among the NERC entities (preferably ones who are still breathing and are willing to make the substantial time commitment required). They draft the new or revised standards and submit them to the NERC ballot body for multiple ballots, each one followed by a comment period in which the SDT members must respond to the questions submitted, followed finally by approval by the NERC Board of Trustees and ultimately FERC.

However, before the SDT can be constituted, a Standards Authorization Request (SAR) needs to be drafted by organizations or individuals with an interest in the changes and submitted to the NERC Standards Committee for approval. Recently, a SAR for BCS and EACMS in the cloud, titled “Cyber Security - Risk Management for Third-Party Cloud Services”, was submitted to the SC; it will be considered (although not necessarily voted on) at the SC meeting.

The main purpose of a SAR is to provide the SDT with “marching orders” that provide sufficient guidance on what the SDT should do. That is, the SAR can’t read, “Hey, please figure out how we’re going to solve the cloud problem and then write a standard to implement that.” It needs to lay out a specific direction for the SDT to follow, without prescribing for them how they’re going to proceed in that direction or what needs to be the result when they get there.

The new SAR (which I believe is the first one regarding the cloud and CIP that has been considered by the Standards Committee) was drafted by three parties, although two joined forces for this effort:

1.      ISO New England and the ISO-RTO Council IT Committee, and

2.      EDF Renewables

While I don’t think the SAR is perfect, I believe it provides enough of a roadmap that the SDT won’t wander in the wilderness when they set out to put pen to paper to develop the cloud standard(s). Moreover, I think the authors have described the most important elements of a solution to the problem, which I tried to describe in this post. These elements include:

1.      A requirement for some sort of certification like FedRAMP or SOC II. The point of having this isn’t that certification is a cure for all problems, but that it almost certainly covers the main IT risks. What is not well addressed by certifications like FedRAMP is risks that apply only to CSPs.

2.      A new scope for CIP. In my opinion (and I think that of the authors of the SAR), the big problem is what I said above: the CIP requirements are applicable to devices, not systems, and a cloud provider can’t track what data are on what devices; their whole model is based on systems. This is not my idea, nor that of the SAR drafters. I got it from the CIP Modifications drafting team, which in 2018 developed a proposal to do away with the concepts of Cyber Asset and BES Cyber Asset (which are the basis of BES Cyber Systems currently), and instead base the standards on BCS from the start. By making BCS the basis of compliance, that means it suddenly doesn’t matter whether the BCS is implemented in physical hardware on premises, in virtualized systems, or in the cloud – a single BCS remains the same if it’s implemented in any of the three environments, or even in all three at once. Unfortunately, that proposal got shot down because a number of large utilities didn’t want to throw away most of the software, training, and procedures they had developed for CIP compliance and go to something completely different. This leads to the next element of the solution:

3.      Two “tracks” for CIP compliance, one for on-premises systems and one for cloud-based systems. In writing the blog post that I linked earlier, I realized it would be very easy to implement this bifurcation in CIP-002 R1 and Attachment 1. This is because the terms Cyber Asset and BES Cyber Asset are not used anywhere in CIP-002 and haven’t been used there since CIP version 5 (which introduced the concept of BCS in the first place) was implemented in 2017. Instead, CIP-002 starts and ends with BES Cyber Systems; very little of substance needs to change (the big change would be in the BCS definition, which would change from its current minimalist definition to one that incorporates most of what is today the BES Cyber Asset definition).

4.      A new CIP standard applicable to BCS and EACMS implemented in the cloud. While the SAR doesn’t say this, I believe the new standard (which might be called CIP-015) needs to focus on the risks that apply specifically to CSPs, since “general IT” risks are already well covered by certifications like FedRAMP.

5.      The standard should include a requirement for the NERC entity to develop a plan to identify, assess and mitigate risks attendant on implementing BCS (and other asset types like EACMS) in the cloud, including risks due to the cloud provider(s) it uses. This would be modeled on CIP-013 R1, although unlike that requirement, it would provide an itemization of areas of cloud risk (e.g., how does the CSP vet the security of third parties that serve as “access brokers” for services in their cloud?) that need to be discussed in the NERC entity’s plan. The plan would not have to mitigate any particular risk, if the entity can show that the risk is so low that it doesn’t apply to them.

6.      The new “Cloud CIP” compliance regime will need to solve the problems with both medium and high impact BES Cyber Systems (BCS) and Electronic Access Control or Monitoring Systems (EACMS), both of which are currently not “allowed” in the cloud at all. However, the EACMS problem is easier to solve, since not as many CIP requirements apply to EACMS as apply to BCS, yet the negative impacts of the EACMS problem (especially on grid security, which of course is exactly what CIP is supposed to be protecting, not undermining) are almost as important as the negative impact of the BCS problem. The SAR suggests that the EACMS problem could be tackled first.

7.      “(The) implementation plan is to allow the possibility for early adoption ahead of any proposed enforceability date.” This is very important. The SAR suggests that the SDT target completion of the new or revised standard(s) and submission to FERC within 12 to 18 months from the “start of SDT deliberations.” This is lightning fast by NERC standards, but after FERC approval (which itself can take up to a year) there is usually a 1-2 year implementation period (that period was two years in the case of the two revised standards that will allow BCSI in the cloud and will take effect on January 1, 2024). Given how long NERC entities have waited to be allowed to implement BCS and EACMS in the cloud, it seems especially cruel to make them wait another two years after FERC has approved all the required changes. “Early adoption” will allow NERC entities who are all ready to move some of their assets to the cloud to do so, while at the same time those who are in no hurry, or have no plans to move any assets at all, don’t have to change anything they’re doing now.

To conclude, I think the SAR now before the Standards Committee should be approved. It’s past time, nd frankly, the costs of not being able to use the cloud are growing all the time. No time like the present!

Any opinions expressed in this blog post are strictly mine and are not necessarily shared by any of the clients of Tom Alrich LLC. If you would like to comment on what you have read here, I would love to hear from you. Please email me at tom@tomalrich.com.

I lead the OWASP SBOM Forum. If you would like to learn more about what that group does or contribute to our group, please go here.


[i] Software-as-a-Service (SaaS) use in the cloud has also been “prohibited”, at least with medium and or high impact BCS. However, the only thing “illegal” about SaaS currently has to do with the fact that SaaS use with BCS will almost always require BES Cyber System Information (BCSI) to be transmitted to and stored in the cloud. For completely different reasons than BCS, BCSI has also officially been “prohibited” in the cloud – although, truth be told, there is at least one SaaS provider that has had customers with medium and/or high impact BCS for at least six years. 

My expectation was that the two revised CIP standards that will come into effect on January 1, 2024 – CIP-004-7 and CIP-011-3 – would fix the SaaS problem once and for all. However, at the moment it seems that may not have happened, due to what seems to be an inadvertent omission in the wording of CIP-004-7 R6. I will write more about that soon.

No comments:

Post a Comment