Wednesday, August 21, 2024

NERC CIP in the cloud: Time for the Hail Mary play?


Last Friday, the Project 2023-09 Risk Management for Third-Party Cloud Services Standards Drafting Team (SDT) held their first meeting. It’s an excellent and very experienced team (for example, one member has served on a CIP SDT since 2008 – and has contributed a huge amount to the CIP standards in that time); I’m looking forward to attending as many meetings as possible.

However, I realized early in the meeting that the team’s current focus is entirely on the Standards Authorization Request (SAR), which serves as the “statement of work” for the project. Like all NERC SARs, this one was first approved by the NERC Standards Committee in December. In some cases, an SDT is allowed to utilize that version of the SAR unchanged, but in other cases (don’t ask me why) the SDT is required, or at least allowed, to make modifications to that version. Whatever the reason, this SDT is going to spend the rest of this year revising their SAR.

I’m not objecting to the SDT revising their SAR, since, even if the team had started to develop new standard(s) right away, they would have needed first to conduct the same sort of fundamental discussions that started on Friday. In Through the Looking-Glass, Alice asks the Cheshire Cat, "Would you tell me, please, which way I ought to go from here?". The Cat replies, "That depends a good deal on where you want to get to”.[i] The SDT knows they’ll never get anywhere unless they first decide where they’re going. The revised SAR will document that decision.

But I also understand that the road ahead for this team is a loooong one. In fact, in this post in January, I estimated that the elapsed time between when the SDT will start developing a new standard and when that standard (plus any required changes to the NERC Rules of Procedure, which also may be needed in this case) would come into effect would be  5 ½ years. Specifically, if the SDT started work on a new standard or standards on July 1, 2024 (as I estimated when I wrote the post), NERC entities could expect compliance with those standards to be mandatory by the end of 2029.

What surprised me on Friday was the SDT’s proposed timeline: It starts with the first meeting and ends in mid-December, when the SDT will turn over their revised SAR to the Standards Committee. What will happen to the revised SAR after the SC gets it? They will probably approve it, which shouldn’t take very long.

However, I’m told that the next step will be for the SAR to be put through the NERC balloting process – the same process that the standards themselves will go through once they’re developed. That process almost always requires multiple ballots by NERC members, as well as comment periods in between the ballots. It's safe to say this step alone will require six months. Only when the SAR has gone through that process will the drafting team be able to get to work on drafting whatever new or revised standards are required.

I was quite disappointed when I heard this, since this the SAR balloting alone will probably add six months to the timeline for the new CIP standards to come into effect. And because I wasn’t expecting that revisions to the SAR would take four months, the two changes add almost a full year to the whole process. Therefore, my new estimate of when the “cloud CIP” standards will become effective is around the end of 2030, or almost 6 ½ years from now.

However, as I pointed out in the January post (and have pointed out in other posts since then), the NERC CIP community can’t wait much longer to be able to make full use of the cloud. This is because more and more software and security service providers are announcing they will soon move exclusively to the cloud, or that they will henceforth make improvements to their product available in the cloud first and only later (or sometimes never) in the on-premises version.

In fact, in the SANS/CTAG webinar today – which you can watch here soon – Ruston Johnson of Splunk showed a chart indicating that updates to their on-premises product will occur more slowly than updates to the cloud product (although he emphasized that they have no plans to discontinue their on-premises product, which evidently had been rumored). Both the security and the reliability of the grid will soon be impacted by this trend, although security has already been impacted by it for years[ii].

So what’s Plan B? In April, I described this possible “shortcut” to full cloud usage, based on a reasonable interpretation of the wording of CIP-013-2 Requirement R1 Part R1.1. This seems even more reasonable to me now, given that I don’t know of any good option other than the “nuclear” one allowed by the NERC Rules of Procedure. That option requires the NERC Board of Trustees essentially to declare a “compliance emergency”[iii]. This would be a last resort and in any case is currently out of the question, since there’s not even discussion of it yet.

As far as I can see, my shortcut doesn’t contradict anything in CIP-013 or any other current CIP standard. However, I admit that NERC entities aren’t likely to try this option, unless there’s a statement by some body within NERC that this is a reasonable interpretation of the wording of CIP-013-2 R1.1. I think it’s time to at least look at this more seriously. Six and a half years is a long time to wait for something that’s essential!

Are you a vendor of current or future cloud-based services or software that would like to figure out an appropriate strategy for selling to customers subject to NERC CIP compliance? Or are you a NERC entity that is struggling to understand what your current options are regarding cloud-based software and services? Please drop me an email so we can set up a time to discuss this!

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] Alice then says, "I don't much care where" and the Cat responds, "Then it doesn't much matter which way you go". It’s hard to argue with that logic!

[ii] I say this because some of the most important security monitoring services are exclusively cloud-based, meaning that, at least since CIP version 5 came into effect in 2016, NERC entities with high or medium impact BES Cyber Systems have not been able to use those services.

[iii] I’m greatly simplifying what this option involves, and “compliance emergency” is my term. The point is that this measure is drastic. It shouldn’t be the first choice for solving this problem.

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