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Two days ago, I participated in two lengthy web
conversations regarding NERC CIP and the cloud. The first was the bi-weekly
meeting of the informal Cloud Technical Advisory Group (CTAG), a group led by
Lew Folkerth of RF and Chris Holmquest of SERC. The group discusses how NERC
entities can make use of the cloud for systems that are subject to compliance
with the CIP standards.
A lot of this group’s discussions are about why there is so
little cloud use by NERC entities today. There are two main reasons:
1.
Most use of the cloud by high or medium impact BES
Cyber Systems (BCS) is impossible today, because the cloud service provider
(CSP) will not be able to provide the NERC entity with the required compliance
evidence for the over 100 CIP Requirements and Requirement Parts that apply to
high and medium impact BCS.
2.
At least two uses of the cloud for BCS are
possible today, including low impact Control Centers and medium or high impact
BES Cyber System Information (BCSI) used in SaaS applications. However, I know
of only a few instances of these uses today. I believe this is because neither NERC
nor the NERC ERO has provided guidance on how to do this, while maintaining CIP
compliance.
The second meeting was a normal meeting of the NERC Risk
Management for Third Party Cloud Services Standards Drafting Team. Of
course, this is very much an official NERC group; they are charged with
drafting new and/or revised CIP standards that should, when put in place, allow
much more extensive use of the cloud by systems subject to CIP compliance, than
is possible today. This team has been meeting for more than a year and a few
months ago started putting virtual pen to virtual paper to draft some real
requirements.
How long will it take before what I call the “Cloud CIP”
standards (i.e., the standards the SDT is drafting) come into effect? The new standards
will be in effect once they have a) been drafted (which will take a at least
1-2 more years), b) gone through at least four ballots by NERC members
(including a two month comment period after each ballot, plus another month for
the SDT to respond to the comments and make changes to the draft standards), c)
been approved by the NERC Board of Trustees, d) been submitted to FERC for
their approval, e) been approved by FERC, most likely more than a year after
they are submitted, and f) gone through a 2-3 year implementation period.
With some luck, all
the above steps will be completed by…drumroll, please…2031. However, I
think even this estimate may be over-optimistic. I say this because I haven’t allowed
for changes to the NERC Rules of Procedure (RoP) – and I think they are likely
to be needed. Since I don’t believe any new or revised CIP standard has ever
required an RoP change, nobody I know can even tell me how this can be
accomplished, except that it’s certain the SDT does not have the power to
do it themselves. Therefore, I can’t quantify the time required for this step. The
best case is that it might be possible to make the RoP changes during the
multiyear implementation period for the “Cloud CIP” standards. If that happens,
my estimated implementation year would remain 2031.
However, one thing I didn’t allow for in my 2031 estimate is
that the SDT might spend a year or two in what turns out to be totally
unproductive activity – for example, if the team spends 1-2 years polishing off
a set of standards that are subsequently rejected by NERC or FERC for being
unenforceable. Were this to happen the SDT would need to start over from the
beginning. This might sound like a joke, but it isn’t – it could very well
happen. Of course, this would be a big disappointment, since it would push the
implementation date for the new standards to 2033 or later.
This is why I’ve decided to create an online Cloud CIP Working
Group whose goal will be to help move up the implementation date for the Cloud
CIP standards. This group will be open to all members of the NERC community who
are concerned about both the arrival time and the quality of the Cloud CIP
standards; this includes NERC entities, NERC ERO staff members, software
vendors, CSPs, consultants, etc.
Fortunately, there is a way to accelerate development
of the new or revised standards. It is to start performing tasks that the SDT
will otherwise need to perform themselves, if they are to produce a quality
product. In other words, I propose to have this new group “break a path” for
the SDT by working on steps that the SDT will inevitably have to take in the
future, if they’re going to produce a worthwhile set of standards.
I want this group to start at the very beginning. The first question
that needs to be answered is, “What is the problem to be addressed in the new
standards?” Cybersecurity is about risk mitigation. A cybersecurity standard
needs to mitigate a certain set of risks. The risks addressed by CIP in general
are those that apply to systems used to maintain the reliability of the Bulk
Electric System.
The problem that the SDT is addressing is the fact that the
current CIP standards, except for three requirements having to do with BCSI
that came into effect on January 1, 2024, were written on the assumption that
all systems in scope will be on premises. At first glance, the solution to that
problem appears to be to rewrite the existing requirements so they take account
of the cloud (in fact, I believe this is the approach the SDT is currently
taking).
However, that approach doesn’t take account of the fact that,
while the wording of the current standards needs to be changed, the bigger
issue is that the entity will need to provide, for each requirement, evidence
that the CSP has complied with the requirement. The CSPs are more than willing
to make available their audit reports for ISO 27001, Soc 2 Type 2 audits, and
FedRAMP, but they are not willing or able to provide evidence for any
requirement that relates to specific devices or network configurations. This is
because cloud data is always spread across devices and data centers. In order
to comply with a requirement like CIP-007 R2 Patch Management, the CSP would
need to identify each device in any data center that might hold just one part
of a BCS during a 3-year audit period; the CSP would need to apply all of the
parts of CIP-007 R2 to every one of those devices.
Of course, this would literally be impossible, but even if
it were, the CSPs would - rightly – never agree to do it, because the cost of
doing so would be astronomical. Moreover, they certainly won’t be able to pass
that cost on to their NERC entity customers, who expect to be on the same rate
schedule as any other customer.
The cloud business model is based on providing the same
services to huge numbers of customers. If 100 NERC entities start requiring
compliance information for over 100 NERC CIP Requirements and Requirement Parts
(which is the number of requirements in scope for each BES Cyber System
or Electronic Access Control or Monitoring System – EACMS – deployed in the
cloud), that will be 10,000 pieces of information per system in scope. If
each of those entities has 100 BES Cyber Systems deployed in the cloud, that
will be one million pieces of compliance information required for just those
100 NERC entities.
This is one reason why any CIP requirement that refers to
particular systems or network configurations will need to be changed, if it is
to apply to cloud-based systems. Moreover, even requirements that don’t apply
to particular systems at all, such as the CIP-008 and CIP-009 requirements, have
a similar problem. This is because they require specific deliverables from the
CSP – e.g., an incident response plan and a backup and recovery plan, as well
as testing of those plans. The CSPs are no more inclined to prepare those plans
for individual NERC entities than they are to provide information on individual
devices.
However, even if the CSPs were able to provide compliance
evidence for the existing CIP requirements, I don’t understand why the drafting
team would even waste their time making the existing CIP requirements
“cloud-friendly”. This is because almost all those requirements are like
provisions that are already covered in ISO 27001 and Soc 2 Type 2 certifications,
as well as FedRAMP authorizations.
Of course, changing the existing CIP requirements won’t
work, since those requirements still need to apply to on-premises systems. What’s
needed is a separate set of Cloud CIP requirements that just apply to BES Cyber
Systems deployed in the cloud (I’ll call them “Cloud BCS”). Each of these would
be intended to address a similar risk to the “equivalent” on-premises CIP
requirement, but it would be based on wording found in a roughly equivalent
requirement in 27001, Soc 2 or FedRAMP. If that is done, the only compliance
evidence required would evidence that the CSP’s audit for the standard in
question didn’t produce any findings for the requirement in question.
For example, Requirement CIP-004-7 Part 5.1 reads, “A
process to initiate removal of an individual’s ability for unescorted physical
access and Interactive Remote Access upon a termination action, and complete
the removals within 24 hours of the termination action (Removal of the ability
for access may be different than deletion, disabling, revocation, or removal of
all access rights).” FedRAMP AC-2.h reads:
The organization notifies account managers when accounts are
no longer required; when users are terminated or transferred; and when
individual information system usage or need-to-know changes.
Of course, this isn’t exactly the same as Part 5.1 – it is
both more comprehensive and less so (there are other FedRAMP requirements that also
correspond to Part 5.1). However, let’s say the drafting team decides that the
wording is close enough that this can be considered a rough equivalent of Requirement
CIP-004-7 Part 5.1. The language of the FedRAMP requirement would be the basis
for a CIP requirement applicable to Cloud-based BCS. The “Measures” section of
the requirement would require evidence of the absence of audit findings for
FedRAMP Requirement AC-2.h.
By using this approach, the SDT will avoid the fate of
developing a bunch of CIP requirements that can’t be audited, since the CSP
will never provide evidence of compliance with a requirement that they consider
to be already covered in ISO 27001, Soc 2 Type 2, or FedRAMP. Compliance
evidence using the approach I’m suggesting will consist solely of pointing to a
particular section in an audit report.
Of course, if a CSP’s evidence is found to comply with a
Cloud CIP requirement by one NERC entity, all other NERC entities should have
the same finding. This means it would be silly to have each NERC entity require
the CSP to provide the same evidence for each Cloud CIP requirement. Instead,
there needs to be a mechanism in which the CSP provides the evidence to NERC
(or some third party designated by them), which then makes it available to each
NERC entity.[i]
Once the SDT drafts “cloud versions” of the existing CIP
requirements, will they be finished? Hardly. Those cloud requirements are based
on just one type of risks: risks addressed in existing CIP requirements. There
are two other types of risk that the SDT (or the group I’m proposing) should
examine, to determine which of those risks are important enough to merit their
own requirements in Cloud CIP.
The second risk type is requirements in ISO 27001, Soc 2
Type 2 and FedRAMP that don’t have “near-equivalent” CIP requirements, but that
are important enough to include in the Cloud CIP requirements. For example,
FedRAMP requirement AC-2.k reads, “The organization establishes a process for
reissuing shared/group account credentials (if deployed) when individuals are
removed from the group.”
This requirement doesn’t match any existing CIP requirement,
but our working group (or the SDT) might decide it addresses a source of risk
that is important enough to warrant its own CIP requirement (applicable to
Cloud BCS, not onsite BCS). Therefore, this requirement could be reworded to be
applicable to Cloud BCS. The “Measures” section of the requirement would call
for evidence of “no findings” in the FedRAMP audit report.[ii]
The third risk type is by far the most important of the
three, since there is no “up front” evidence (such as a certification or
authorization) that the CSP has already mitigated risks of this type. This
third type consists of risks that only apply to cloud-based systems.
Since both ISO 27001 and FedRAMP can apply to both on premises and cloud-based
systems, I believe they don’t include cloud-only risks (although I’m open to
correction if someone knows otherwise).
Three cloud-only risks that I’ve identified just by reading
the news are:
1. The CSP doesn’t make sure their customers are
adequately trained in the security measures required to protect their cloud
environment. As I described in this
post, Paige Thompson, the woman who single-handedly almost brought down
Capitol One, was a technical staff member who had recently been fired by a CSP.
She got revenge by breaking into the cloud environments of at least 30
customers of that CSP, one of which was Capitol One. She bragged online that all
those customers had made the same mistake in configuring their security
controls; moreover, she said there were many other customers that made that
mistake.
Of course, the CSP shouldn’t be held responsible for every
configuration mistake made by a customer. However, if 30+ customers have all
made the same mistake, that’s clearly a problem that needs to be addressed by
the CSP. And the answer can’t be, “We offered a class for $695 that included
discussion of this issue, but they didn’t take it.” The CSP should provide the
training for free, if reasonably security-proficient customers are prone to make
a serious mistake like this one.[iii]
If this risk were to be addressed in a CIP requirement, the
requirement might call for the CSP to explain what they are doing to make sure
their customers understand how to securely configure their cloud environment.
2. The CSP didn’t vet their online access
providers’ security properly. The Russian attackers that perpetrated the
SolarWinds attack were quite smart. Perhaps the smartest thing they did was to conduct
a classic supply chain attack by conducting their attack on the SolarWinds
development environment by first compromising a popular SaaS application used
by SolarWinds. They did that by first compromising
a third party that sells access to that SaaS application. Through that third
party, they gained access to the cloud environment on which the SaaS
application was running (the SaaS app itself was not compromised). From that
environment, they launched the entire attack on SolarWinds (which was without
much doubt one of the most
sophisticated cyberattacks of all time).
Of course, the solution to this problem is for the platform
CSP to tighten security requirements on the third party access brokers. A CIP
requirement to address this risk might ask the CSP to describe the security
requirements they place on third party access brokers and how they enforce
them, as well as whether they have experienced any breaches through these
access brokers.
3. Cloud Hopper. This attack was revealed in a
Wall
Street Journal article[iv]
by Rob Barry and Dustin Volz in 2018. What’s most scary about it is that the
attackers were able to jump from customer to customer within the clouds of
multiple CSPs, and that they used a variety of techniques to penetrate
different customers. This shows that your security in the cloud is at least
partially dependent on whether your fellow cloud customers also practice good
security – i.e., it’s a kind of herd immunity.
Of course, a platform CSP can’t police the general
cybersecurity practices of all companies that utilize their cloud. However, the
CSP should have measures in place today to detect and counteract
attempts to hop from one customer to another. A CIP requirement might ask the
CSP to describe (at least in general terms) the measures they have in place, as
well as whether those measures have been successful in preventing Cloud
Hopper-type breaches.
Of course, the three risks listed above are not the only
cloud risks faced by NERC entities! The primary task of the group I want to
form will be to review cloud risks identified by various organizations –
federal agencies, the military, CSPs themselves, etc. – and decide which of
them should be included as the basis for Cloud CIP requirements.
You may have noticed that, when I reached cloud-only risks
(the third type of cloud cybersecurity risks), I abandoned my earlier concern
that the CSPs won’t be willing to provide answers to unique questions like these.
This is because the first two types of risks are already addressed in ISO 27001
and FedRAMP, with which the CSP is presumably already compliant. To provide
evidence of compliance for CIP requirements based on those two types of risks, the
CSP can simply point the customer to the audit reports.
However, risks of the third type – cloud-only risks – aren’t
addressed by those other standards. Therefore, the CSP should feel obligated to
provide compliance evidence for CIP requirements based on those risks. Again,
since the CSP’s response to any of these requirements will be the same for all
NERC entities, NERC, or a third party designated by them, should be the single
point of contact for the CSP.
NERC will “audit” each of the CIP cloud-only risk requirements
by evaluating the CSP’s response to a question or small set of questions, e.g.,
“Describe the security requirements you place on third party access brokers and
how you enforce them. Have you experienced any security breaches that came through
one of these access brokers?” The response will be evaluated by asking and
answering the question whether the CSP has adequately mitigated the risk that
is the basis for the CIP requirement. If the response has not convinced NERC
(or the third party) that the CSP has mitigated that risk, they will need to
ask the CSP for more evidence.
The problem with the process I’ve just described is that it’s
not currently allowed by anything in the NERC Rules of Procedure. As I’ve
already said, I doubt there is any way to implement this process without making
RoP changes.
However, in my opinion these cloud-only risks should be the
primary focus of evaluation of the CSPs. This is because the fact that the
major CSPs have all passed ISO 27001 and Soc 2 Type 2 audits, and have all been
authorized for use by federal agencies under FedRAMP, means they don’t present a
big problem when it comes to “normal” risks, like lack of patch management or
configuration management programs. It’s fine to have Cloud CIP requirements
that apply to normal risks, but the only compliance evidence the CSPs should
have to provide is what’s in their audit reports based on those three
compliance regimes (and perhaps others as well).
On the other hand, I strongly doubt that the cloud-only
risks I’ve listed (and many more identified by others) are found in any
standard compliance regimes today. The working group I want to put together
will have one primary responsibility: compile a list of cloud-only risks that
are not currently addressed by standard compliance regimes, then decide which
of these are important enough to be addressed in the Cloud CIP standards. You’re
welcome to participate in this effort if you are with a NERC entity, a vendor
of cloud or software services to NERC entities (including SaaS providers and
platform CSPs), NERC or the NERC ERO, a consulting organization that provides
services based on NERC CIP, or if you’re just a user of electricity.
If you don’t use electricity, you obviously have no stake in
what this group will do, so you’re not welcome. On the other hand, if you don’t
use electricity, I’d like to know how you’re reading this blog post.
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 or
comment on my free Substack community chat.
[i]
There’s no mechanism today by which NERC can receive audit evidence from a
third party and distribute it to individual entities. This is one reason why I
think there will need to be changes to the NERC Rules of Procedure. As you’ll
see later in this post, this isn’t the only reason why I think that.
[ii] It’s
possible that the SDT (or our Cloud CIP Working Group) might decide that, if
the CSP has received the appropriate certifications (ISO 27001 and Soc 2 Type
2) and authorization (FedRAMP), there’s no need to consider the other
requirements in the certification or authorization, besides those that map to
CIP requirements. This is because the certification means the CSP has either received
no audit finding on each requirement, or they received a finding but have already
mitigated the risk satisfactorily.
Therefore, the SDT and/or the Cloud Security Working
Group might just skip this second risk type altogether and address the third risk
type. The third type is much more important than the first two, since risks of
the third type presumably are not already addressed by any of the three
compliance regimes.
[iii] After
my posts on this incident appeared in 2018, I and Dick Brooks of Reliable Energy Analytics talked
with someone from that CSP, who had contacted me about those posts. They convinced
me that they had already addressed the problem (the meeting was at least a year
after the incident).
[iv] The linked article was originally
made open access but may have slipped behind the paywall. Rob Barry gave me a
link to a PDF of the article on his personal website; if you can’t access the
article itself, email me and I’ll send you that link.
