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@RFirst_Corp Follow us on LinkedIn and Twitter Forward Together ReliabilityFirst Enforcement Trends & Addressing Silos Patrick OConnor, Counsel Kristen Senk, Senior Counsel Agenda Topics Update on enforcement trend data
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4 132 90 63 31 23 17 17 16 13 12 CIP-007 CIP-010 CIP-004 CIP-006 PRC-024 CIP-005 MOD-025PRC-005 PRC-019 CIP-011 Number of Violations
12 Month Rolling Count
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111 316 16 26 16 4 11 37 62 50 100 150 200 250 300 350 2016 2017 2018 Dismissal/CE FFT Settlement 5
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746 671 293 329 310 100 200 300 400 500 600 700 800 2014 2015 2016 2017 2018 By Date Reported Average Days from Start Date to Report Date 6
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with the CIP Standards
worked with Registered Entities to identify the themes and resolutions.
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* The graph
represents the violations that concern the more significant CIP compliance deficiencies. 45% 29% 11% 15%
Disassociation Organizational Silos Inadequate Tools Lack of Awareness
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Generation
units, and different levels of management
Vertical Silos
(Between Business Units or Departments)
Horizontal Silos
(Between Layers from the Top Down)
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Bill Edwards
Assistant General Counsel Exelon Corporation
Thomas Breene
Manager FERC/NERC Compliance WEC Energy Group Business Services
Kristina Pacovsky
Managing Senior Corporate Counsel Midcontinent Independent System Operator
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April 26, 2018 Columbus, OH
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Slide 1 of 237
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GridEx IV Exercise - 2017
and emergency response exercise, GridEx IV, on November 15–16, 2017
exercise and a separate executive tabletop on the second day
stakeholders in the electricity sector to respond to simulated cyber and physical attacks affecting the reliable operation of the grid
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Cyber Attack Scenario
(ICS) such as process control systems, energy management systems, distribution management systems, and supervisory control and data acquisition systems (SCADA) used to operate generating units, transmission substations, and control centers. The attacks disrupt the ability of power system operators to monitor and control the reliability of the bulk power system (BPS)
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Physical Attack Scenario
cause large-scale power outages, while avoiding immediate and deliberate degradation to the level that would move the exercise into black start restoration plan scenarios. Voice and data communications systems used by BPS operations and security personnel are also affected by physical attack, hindering their ability to respond to the situation
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Communications Challenges
exercise how they receive and share information with external stakeholders, including customers, local government officials, and the general public
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GridEx IV Exercise - Objectives
response
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GridEx IV Exercise - Participation
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GridEx Exercise – Lessons Learned
require more integration into the master scenario
together to further operationalize the Cyber Mutual Assistance (CMA) Program
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GridEx IV Exercise – RF Participation
Corporate Communications Teams, and the CSO
following the master scenario events as played out by electric utilities in
custom scenario which was created and played out simulating an RF data breach event
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GridEx IV Exercise – RF Participation (cont.)
following the exercise master scenario events as played out by electric utilities and also responding to the RF data breach event coordinating with IT, the CSO, and Executives
interacting with EASA, IT, Corporate Communications, and Executives for both the master scenario events and the custom RF data breach scenario
Team acting as RF users affected by the RF Data Breach event
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GridEx IV Exercise – RF Lessons Learned
(internal & external)
exercises to test our response capabilities more completely
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GridEx IV Exercise – Follow on Activities
GridEx IV After Action Report
Lessons Learned
Response and Recovery (CyPReS) Study
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Why participate in GridEx Exercises?
recover from simulated coordinated cyber and physical security threats and incidents
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Slide 237 of 237
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Forward Together ReliabilityFirst
Standard Drafting Team Outreach Slides
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Agenda
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provide controls to protect, at a minimum, communication links and data communicated between bulk electric system Control Centers are necessary in light of the critical role Control Center communications play in maintaining bulk electric system
section 215(d)(5) of the FPA, develop modifications to the CIP Reliability Standards to require responsible entities to implement controls to protect, at a minimum, communication links and sensitive bulk electric system data communicated between bulk electric system Control Centers in a manner that is appropriately tailored to address the risks posed to the bulk electric system by the assets being protected (i.e., high, medium, or low impact).” SAR – FERC Directives
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Obligations
particularly if the TO has the ability to operate switches, breakers and relays in the BES.
SAR – V5TAG I tems
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virtualization:
applicable, EACMS/PACS with BCS, Low/Medium/High BCS, EACMS/PACS with non-CIP applicable, etc.). Clarify in requirements/definitions/guidance the permitted architectures and control necessary to permit them.
management control, and physical hardware
including identifying any differences in treatment between classes.
the ESP and one VLAN outside the ESP.
be treated differently than other EACMS
SAR - Virtualization
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4.
quarter that is three (3) calendar months after the effective date.
CI P-002-6a Modifications
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2.12. Control Centers or backup Control Centers, not included in High Impact Rating above, that monitor and control BES Transmission Lines with an "aggregate weighted value" exceeding 6000 according to the table below. The "aggregate weighted value" for a Control Center or backup Control Center is determined by summing the "weight value per line" shown in the table below for each BES Transmission Line monitored and controlled by the Control Center or backup Control Center.
CI P-002-6a Modifications
Voltage Value of a Line Weight Value per Line less than 100 kV (not applicable) (not applicable) 100 kV to 199 kV 250 200 kV to 299 kV 700 300 kV to 499 kV 1300 500 kV and above
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related to Planned and Unplanned Changes language that was previously found in the Implementation Plan
implementation plan to the standard.
a new section in the standard will be added to identify timelines based on changes to a BES asset or Cyber Asset Planned/ Unplanned Changes
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were planned and implemented by the Responsible Entity or with the Responsible Entity’s awareness. Planned Changes typically involve a change to a Bulk Electric System asset (e.g., substation, generating resource, Control Center) or a change to a Cyber Asset that was foreseen by the Responsible Entity. Examples of Planned Changes include: (1) placing a new transmission substation into service or adding a new line to an existing substation; (2) placing a new BES generation resource into service or adding a generation resource to an existing plant; (3) placing a new primary or backup Control Center or associated data center into service or implementing a new supervisory control and data acquisition (SCADA) system or energy management system (EMS) or an upgrade to an existing SCADA system or EMS; (4) implementing a project for substation automation where Cyber Assets are installed, upgraded, or replaced such as electromechanical relays being replaced with digital relays; or (5) implementing a control system upgrade at a generating resource. Planned/ Unplanned Changes
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Asset that occur without the entity’s awareness or (ii) changes to the categorization of a Cyber Asset caused by a notification from another entity or the output of a planning
notified (internally or externally) that a generation Facility has been designated as necessary to avoid an Adverse Reliability Impact in the planning horizon of more than
notified (internally or externally) that a generation or Transmission Facility has been identified as critical to the derivation of an IROL and their associated contingencies (CIP-002, Attachment 1, Criterion 2.6); (3) when a generating resource that is connected at less than 100kV is designated as a new Blackstart Resource along with its Cranking Path (CIP-002, Attachment 1, Criterion 3.4); or (4) when a system study that shows changes in customer load have resulted in crossing the 300 MW threshold of a load shedding system as described in Criterion 2.10 of CIP-002, Attachment 1. Planned/ Unplanned Changes
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Planned and Unplanned Changes: If a Responsible Entity has a Planned Change or Unplanned Change, the Responsible Entity shall comply with the requirements in this Reliability Standard in accordance with the following: For Planned Changes resulting in a new BES Cyber System or a change in categorization for an existing BES Cyber System, the Responsible Entity shall comply with all newly applicable requirements in this Reliability Standard upon the commissioned date of the Planned Change. For this provision, the commissioned date is the date a new or modified Bulk Electric System asset or Cyber Asset is capable of impacting the BES. For requirements that contain periodic obligations, initial performance of those obligations following a Planned Change shall occur within the first period following the commissioned date of the Planned Change. Planned/ Unplanned Changes
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For Unplanned Changes, the Responsible Entity shall comply with all newly applicable requirements in this Reliability Standard according to the timelines in the table below. As used in the table, the phrase “BES asset type” refers to the following BES asset types listed in Requirement R1 of CIP-002: (i) Control Centers or backup Control Centers; (ii) Transmission stations or substations; (iii) generation resources; (iv) systems and facilities critical to system restoration including Blackstart Resources and Cranking Paths and initial switching requirements; (v) Special Protection Systems that support the reliable
Systems specified in Applicability section 4.2.1. Planned/ Unplanned Changes
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Scenario of Unplanned Change Implementation Period New high impact BES Cyber System associated with a BES asset type where the Responsible Entity has previously identified a medium or high impact BES Cyber System associated with that same BES asset type 12 calendar months from the date of notification or detection of the Unplanned Change. New high impact BES Cyber System associated with a BES asset type where the Responsible Entity has not previously identified a medium or high impact BES Cyber System associated with that same BES asset type 24 calendar months from the date of notification or detection of the Unplanned Change. New medium impact BES Cyber System associated with a BES asset type where the Responsible Entity has previously identified a medium or high impact BES Cyber System associated with that same BES asset type 12 calendar months from the date of notification or detection of the Unplanned Change.
Planned/ Unplanned Change (Part 1 of 2)
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Planned/ Unplanned Changes (Part 2 of 2)
New medium impact BES Cyber System associated with a BES asset type where the Responsible Entity has not previously identified a medium or high impact BES Cyber System associated with that same BES asset type 24 calendar months from the date of notification
Unplanned Change. New low impact BES Cyber System associated with a BES asset type where the Responsible Entity has previously identified a low, medium, or high impact BES Cyber Systems associated with that same BES asset type 12 calendar months from the date of notification or detection of the Unplanned Change. New low impact BES Cyber System associated with a BES asset type where the Responsible Entity has not previously identified a low, medium, or high impact BES Cyber systems associated with that same BES asset type 24 calendar months from the date of notification or detection of the Unplanned Change.
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For requirements that contain periodic obligations, initial performance of those
the date that the Implementation Period ends, as defined in the table above. For Unplanned Changes resulting in a higher categorization for an existing BES Cyber System, the Responsible Entity shall continue to comply with the applicable requirements of the prior categorization during the Implementation Period defined above. Planned/ Unplanned Changes
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CI P-012-1 Modifications
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disclosure or modification of Real-time Assessment and Real-time monitoring data, while being transmitted between any Control Centers. This requirement excludes oral communications. The plan shall include: [Violation Risk Factor: Medium] [Time Horizon: Operations Planning] 1.1 Identification of security protection used to mitigate the risk of unauthorized disclosure or modification of Real-time Assessment and Real-time monitoring data while being transmitted between Control Centers; 1.2 Identification of where the Responsible Entity applies security protection is applied for transmitting Real- time Assessment and Real-time monitoring data between Control Centers; and 1.3 When the by different Responsible Entities own or operate Control Centers identify the responsibilities of each Responsible Entity for applying security protection to the transmission of Real-time Assessment and Real-time monitoring data between those Control Centers.
CI P-012-1 Modifications
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definition of Control Center, but that the team thought were not consistent with the spirit of the definition Control Center Definition
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including field switching personnel
today’s renewable generation is built
the registered entities. Control should include the concept of jurisdictional authority and the ability to issue directives such as in the case of an RC control system that may not have the capability to open and close breakers directly
definition of Real-time, but ultimately weighed in favor of consistency with the use of the term based on its inclusion in the PER-005-2 standard
definition to make specific inclusions and exclusions. This model was based on the BES definition which also has specific inclusions and exclusions as part of the definition.
Control Center Definition
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One or more facilities, including their associated data centers, that monitor and control the Bulk Electric System (BES) and also host operating personnel who: 1) perform the Real-time reliability-related tasks of a Reliability Coordinator; or 2) perform the Real-time reliability-related tasks of a Balancing Authority; or 3) perform the Real-time reliability-related tasks of a Transmission Operator for Transmission Facilities at two or more locations; or 4) can act independently as the Generator Operator to develop specific dispatch instructions for generation Facilities at two or more locations; or 5) can operate or direct the operation of a Transmission Owner’s Bulk Electric System Transmission Facilities in Real-time. Operating personnel do not include: 1) plant operators located at a generator plant site or personnel at a centrally located dispatch center who relay dispatch instructions without making any modifications; or 2) Transmission Owner or Transmission Operator field switching personnel.
Control Center Definition
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Virtualization
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Next Steps
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Conference Dial-in
Reserved Call Times
calendar of events for the most updated information. Issue Area Working Calls--Scheduled if needed on the NERC Standards Calendar
needed to allow the sub-teams to process input and develop proposals.
Conference Call Schedule
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2018 Planned Dates:
SDT Meeting Schedule
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Project Page under Related Files: Project 2016-02 Modifications to CIP Standards
Jordan.Mallory@nerc.net 404.446.2589 (Office)
Resources
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Forward Together • ReliabilityFirst
Forward Together • ReliabilityFirst
Threat Intelligence
Threat intelligence reduces harm by improving decision making before, during, and after cybersecurity incidents reducing operational mean time to recovery and reducing adversary dwell time
Threat intelligence is previously unknown knowledge of malicious cyber activity enabling better decision making in network protection and response
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Wha What adversaries use, including their capabilities and infrastructure Who Who adversaries are, comprising the actors, sponsors, and employers Wher Where adversaries target, detailing industries, verticals and geographic regions When When adversaries act, identifying timelines and patterns of life Why Why adversaries attack, including their motives and intent Ho How adversaries operate, focused on their behaviors and patterns
What is the threat? Addressing who, what, where, when, why, and how.
Threat Intelligence “3 Question Rule”
All threat intelligence should answer three questions enabling the audience to quickly identify the relevance and impact to their organization followed by immediate action if necessary.
What is the impact to an organization if the threat were realized? Which actions mitigate the threat in both the near and mid-term?
Context describes the threat and proves or disproves the relevance and impact to the audience. “Context is king” helping organizations properly prioritize their action and response when overwhelmed with alerts & alarms.
Threat Intelligence: A Composite of Two Elements
Threat intelligence is comprised of two elements: context and action. Without either intelligence is neither actionable nor understandable.
Action provides technical and policy recommendations customized for the threat, its behavior, and impact.
Detect
threats using threat behavior analytics
Respond
threats through incident response
Prevent
prevent through policy, education, and technology
Integrating Threat Intelligence Across the Security Process
Security Operations Network Defenders Incident Response Technical indicators and behaviors to inform network- level action and remediation
Threat Intelligence Type Audience Description
Threat Hunters Incident Response Security Leadership Security Leadership Organizational Leadership Intelligence on adversary behavior informing: holistic remediation, threat hunting, behavioral detection, purchasing decisions, and data collection Places threat into a business context and describes strategic impact informing risk management and
Intelligence on activities of adversaries known to have an interest in control systems and operational networks
ICS Threat Intelligence Categories
ICS threat intelligence falls into three categories – intelligence not conforming to these categories generally does not support industrial control security demands.
Example: DRAGONFLY compromises victim networks to gather information on their industrial control system and related operations but have not yet been identified as disrupting or directly interfacing with industrial control systems Intelligence on threats directly affecting the operation of industrial control systems Example: CRASHOVERRIDE is a malware framework designed and deployed to disrupt electric power transmission Intelligence on threats not associated with industrial control systems but have a high likelihood of disrupting their operation Example: WANNACRY ransomware does not target industrial control systems but it’s capability has shown to be debilitating to organizations when it can access
Dragos’ 2017 in Review reports revealed that for ICS vulnerabilities:
A short and easily-understood description of the vulnerability accessible to most security professionals
Vulnerability Description Elements
Vulnerability analysis is necessary for complete threat intelligence. Threat intelligence producers must include four elements of information about a vulnerability to ensure good decision-making.
Understanding the vulnerability in the threat environment, including active exploitation and the scope and scale of such use The potential impact of the vulnerability when leveraged by an adversary The actions available to defenders to prevent or reduce the risk of the vulnerability impacting operations
A producer must have the data sources and visibility into the threats affecting the customer’s environment. Without the proper data there can be no relevant intelligence.
Distinguishing Threat Intelligence Products
Three elements clearly distinguish threat intelligence products. An evaluation of any threat intelligence product and producer should examine these elements which will help a customer select the best ones for their business.
A producer must have an understanding of the customer’s business in
must translate all intelligence into their domain themselves. A producer must understand the customer’s operations so that they may recommend proper actions without causing undue harm or simply stating generic best practices.
Threat intelligence must provide sufficient detail to enable a proper response
CART: Identifying Good Threat Intelligence
Inaccurate threat intelligence is worse than no threat intelligence and any quality threat intelligence must be accurate Threat intelligence must address only relevant threats to the organization and be delivered in a method that allows for effective action Threat intelligence must be produced and delivered quickly so that it can be and used fast enough to make a difference
Threat Intelligence: Measuring Return on Investment (ROI)
Mean Adversary Dwell Time
The time measured between when an adversary first gained unauthorized access to a network/system and when incident response successfully severed adversary access and control
Mean Time to Recovery
The time from when an adversary first causes an operational disruption to when
ICS tailored malware families
E
Intent to disrupt industrial processes
Identified in 2017
First malware to target grid operations
target SIS
CHRYSENE
Links OilRig, Greenbug
IT compromise, information gathering and recon against industrial orgs
Victimology Oil & Gas, Manufacturing, Europe, MENA,
Capabilities Watering holes, 64- bit malware, covert C2 via IPv6 DNS, ISMDOOR
COVELLITE
Links Lazarus, Hidden Cobra
IT compromise with hardened anti-analysis malware against industrial orgs
Victimology Electric Utilities, US Capabilities Encoded binaries in documents, evasion techniques
DYMALLOY
Links Dragonfly2, Berserker Bear
Deep ICS environment information gathering,
industrial process details
Victimology Turkey, Europe, US Capabilities COODOR, DORSHEL, KARAGANY, Mimikatz
ELECTRUM
Links Sandworm
Electric grid disruption and long-term persistence
Victimology Ukraine, Electric Utilities Capabilities CRASHOVERRIDE
MAGNALLIUM
Links APT33
IT network limited, information gathering against industrial orgs
Victimology Petrochemical, Aerospace, Saudi Arabia Capabilities STONEDRILL wiper, variants of TURNEDUP malware
ALLANITE
Links Palmetto Fusion
Watering-hole and phishing leading to ICS recon and screenshot collection
Victimology Electric utilities, US & UK Capabilities Powershell scripts, THC Hydra, SecretsDump, Inveigh, PSExec
XENOTIME
Links None
Focused on physical destruction and long-term persistence
Victimology Oil & Gas, Middle East Capabilities TRISIS, custom credential harvesting
Since 2014 Since 2017 Since 2016 Since 2016 Since 2016 Since 2017 Since 2017
Penetrate ICS Network Establish Foothold Enumerate Systems & Protocols Deliver Attack
Takes time, access, and work
ELECTRUM: Disrupting Electric Power Transmission
Establish Access
System Transfer TRISIS Base Module to System Use TRISIS Base Module to Compromise SIS Upload Follow-On Payloads
XENOTIME: Attacking Safety Systems and a Threat to Life
Enable two-factor (not phone factor) authentication across internal assets and services
Control IT-OT boundary
Audit and secure safety systems
Add OT monitoring, look for behaviors, not indicators
Get ICS threat intelligence
Larry Bugh, Chief Security Officer & Director EASA April 26, 2018
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Executive Committee
Ross Johnson, Phys SME, Capital Power Marc Child, Chair, Great River Energy Melanie Seader, EEI Brenda Davis, Cyber SME, CPS Energy David Grubbs, Vice Chair, City of Garland (vacant) APPA Lisa Carrington, Ops SME, Ariz Public Svc David Revill, Vice Chair, NRECA (vacant) EPSA Jeff Fuller, Policy SME, AES (vacant), Secretary, NERC (vacant) IPC
Physical Security Subcommittee
(Ross Johnson)
Cybersecurity Subcommittee
(Brenda Davis)
Operating Security Subcommittee
(Lisa Carrington)
Policy Subcommittee
(Jeff Fuller) Physical Security WG (PSAG)
(Ross Johnson)
Control Systems Security WG
(Mike Mertz) (Carter Manucy)
Grid Exercise WG
(Tim Conway)
Security Metrics WG
(Larry Bugh)
Compliance and Enforcement Input WG
(Paul Crist)
Physical Security Guidelines TF
(Darrell Klimitchek)
Security Training WG
(David Godfrey) (Amelia Sawyer)
Planning Committee Joint Project
Criticality Reduction
(Vacant)
Supply Chain Working Group
(Vacant)
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Key updates to CIPC Charter:
deliverables of CIPC
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2018 – 2019 Strategic Plan & Work Plan
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Plan available at https://www.nerc.com/comm/CIPC/Related%20Files%20DL/CIPC%20Strategic%20Plan%202018-2019.pdf
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emerging risks and issues pertinent to the security of BES
subcommittees
proactive resolution of issues
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Enterprise Long Term Strategy
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Enterprise Long Term Strategy
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clarification on compliance monitoring or enforcement with the following documents:
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direction, technical oversight, feedback on the collection of industry metrics, and reporting of BES security performance metrics.
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for both physical and cyber security to various industry segments.
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# CIPC Deliverable (non-ongoing projects) Estimated Completion Date 1 Implications of Voice-over-IP and the CIP Standards Q1 2018 2 Develop CIPC Collaboration Site on NERC.com Q2 2018 3 CIP Implications of Shared Transmission Facilities Q2 2018 4 Key management security guideline Q2 2018 5 Vendor Essential Security Practices Model Q3 2018 6 Security implications of UAVs Q3 2018 7 Update CIPC Website on NERC.com Q3 2018 8 Implications of Cloud Services for CIP Assets Q4 2018 9 Assess the cyber security risk of Fuel Handling SCADA systems for Generation Q1 2019 10 Address Remote Access Security Findings #1-#18 Q3 2019 11 Identification and Reduction of Cyber and Physical Security Risks Q4 2019 12 Legacy system testing coordination with National Labs Q4 2019 13 Annual Security Assessment of the BES Q4 2019
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