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Critical Infrastructure Protection
Standards Activities
The following standards related
critical infrastructure protection activities are currently underway:
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Project
2008-14 Cyber Security Violation Severity Levels
– The purpose of this project is to propose Violation Severity
Levels (VSLs) for the version 1 CIP-002 thru CIP-009 standards as
directed in FERC Order 706.
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Project
2008-06 Cyber Security Order 706 -
The purpose of this project is to review each of the cyber security
standards to ensure that they conform to the latest version of the
ERO
Rules
of Procedure, including the
Reliability Standards Development Procedure, to address the directives identified in FERC
Order 706, and to issues identified by industry stakeholders. This
project includes making conforming changes to violation risk factors
and violation severity levels to align with modifications made to
the requirements.
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Development of a Technical Feasibility Exception (TFE) Procedure
– NERC staff is drafting a
Procedure for Requesting and Receiving a Technical Feasibility Exception
to NERC Critical Infrastructure Protection Standards.
The intent is to file this procedure as an amendment to the
ERO Rules of Procedure.
Background
Project
2008-14 Cyber Security Violation Severity Levels
On August 7, 2008 the NERC Standards Committee appointed the
drafting team for Project 2008-14 Cyber Security Violation Severity
Levels. This drafting team was assigned the responsibility of proposing
VSLs for the version 1 Cyber Security standards (CIP-002-1 through
CIP-009-1). This drafting
team is working in parallel with the Standard Drafting Team (SDT) for Project 2008-06
Cyber Security Order 706 is expected to coordinate the development of VSLs for the
version 2 Cyber Security standards (CIP-002-2 through CIP-009-2).
Project
2008-06 Cyber Security Order 706
The SDT for Project 2008-06 Cyber Security
Order 706 was appointed by the NERC Standards Committee on August 7,
2008 to develop revisions to the NERC Critical Infrastructure Protection
(CIP) Reliability Standards on Cyber Security (CIP-002-1 through
CIP-009-1). The SDT was
assigned to review each of these cyber security standards to ensure that
they conform to the latest version of the ERO
Rules
of Procedure, including the
Reliability Standards Development Procedure, to address the
directives identified in FERC Order 706, and to issues identified by
industry stakeholders.
This suite of reliability standards covers a broad
range of topics with respect to cyber security requirements as
identified in:
CIP-002-1 Critical Cyber Asset Identification
CIP-003-1 Security Management Controls
CIP-004-1 Personnel & Training
CIP-005-1 Electronic Security Perimeter(s)
CIP-006-1 Physical Security of Critical Cyber Assets
CIP-007-1 Systems Security Management
CIP-008-1 Incident Reporting and Response Planning
CIP-009-1 Recovery Plans for Critical Cyber Assets
The SAR for this project indicates that the SDT
will consider other cyber-security related standards, guidelines, and
resources that are presently available and are followed by a variety of
organizations. These
organizations include the National Institute of Standards and Technology
(NIST) Security Risk Management Framework, the NERC Critical Infrastructure
Protection Committee (CIPC) Risk
Assessment Guideline, the Department of Homeland Security (DHS), the
Department of Energy (DOE), as well as various standards organizations
such as the International Electrotechnical Commission (IEC), the
International Society of Automation (ISA), the Institute of Electric and
Electronic Engineers (IEEE), and others.
Multiphase
Approach Strategy
In October 2008, the SDT agreed that due to the extensive scope and
varying complexity of the issues and the work involved in making these
revisions to the cyber security standards, a multiphase approach for
revising this set of standards was needed and was therefore adopted.
The “Phase 1” revisions are limited to
modifications to the cyber security standards (CIP-002-1 through
CIP-009-1) to comply with the near term specific directives included in
FERC Order 706 and 706A, and revisions that were not expected to invoke
significant industry debate.
The Phase 1 revisions address the directive in FERC Order 706 that the
“… ERO modify the CIP Reliability Standards through its Reliability
Standards development process to remove references to ‘reasonable
business judgment’ before the compliance audits begin in 2009.”
The more complex issues in this project, such as consideration of
the applicable features of the National Institute of Standards and
Technology (NIST) standard framework described in NIST 800-53 as well as
the identification of what cyber equipment should be addressed by the
CIP-003 through CIP-009 standards, will be addressed in subsequent
phases of this project.
Violation Risk Factors
The SDT for Project 2008-06 Cyber Security Order is
responsible for proposing Violation Risk Factors (VRFs) for the version
2 Cyber Security standards (CIP-002-2 through CIP-009-2) that are
consistent with the modifications to any requirements in these
standards. The only VRF that
is proposed for modification is associated with the changes made in
standard CIP-006-2.
Technical
Feasibility Exception (TFE) Procedure
At the suggestion of the SDT for Project 2008-06 Cyber Security
Order 706, NERC staff is proposing an amendment to the ERO Rules of
Procedure which will provide Responsible Entities with a mechanism for
requesting and receiving approval for an exception from the terms of
certain requirements in the Cyber Security standards on the grounds of
technical feasibility or technical limitations.
Without this TFE procedure, each entity would have to submit a
request for a variance, following the process outlined in the
Reliability Standards Development Procedure.
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