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If you’re interested in the NERC CIP “cloud problem”, you
may know that I’ve been pointing out for a while that:
1.
Use of BCSI (BES Cyber System Information) in
the cloud has been “legal” since two revised NERC standards, CIP-004-7 and
CIP-011-3, came into effect on January 1, 2024. The main reason why this is
important is that, before that date, NERC entities with high and/or medium
impact BES environments couldn’t officially use SaaS (i.e. cloud-based software)
products that require BCSI access.
2.
However, since that date, very few (if any) new
SaaS products that use BCSI have been introduced, probably because few NERC
entities today feel they understand
the new and revised BCSI requirements well enough to comply with them.
3.
NERC entities especially need to understand what
compliance documentation their SaaS provider will need to give them, since few
if any SaaS providers to the power industry today even know they have a role to
play in complying with the two revised standards.
Unfortunately, neither NERC nor
any of the Regions (to my knowledge) has stepped up to fill this understanding
gap using webinars or other means. Until last week, when NERC announced a
webinar on the topic to be held on September 29; signup is here.
NERC’s description of the webinar is:
The ERO Enterprise will conduct a webinar on September 29,
2025 at 1:00 p.m. Eastern to provide information on protections and controls
related to BES Cyber System Information (BCSI) in the cloud. The webinar will
review examples, considerations, and best practices.
Since I’m not involved in this
webinar and don’t know the presenters (two CIP auditors, I believe), I can’t
tell you in advance whether it will be good or mediocre (I’m sure it won’t be
bad). I can say it’s worth watching, if you’re at all involved with this
question.
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,
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