By Gregory Hale
Federal Energy Regulatory Commission (FERC) wants to require new or modified critical infrastructure (CIP) standards to address growing risks to compromise the bulk-power system.
The proposal would direct the North American Electric Reliability Corporation (NERC) to require entities to identify their current supply chain risks to their grid-related cybersecurity systems at specified intervals; assess and take steps to validate the accuracy of the information received from vendors during the procurement process; and document, track and respond to these risks to their systems.
FERC would also direct NERC to extend the applicability of the supply chain standards to include a category of products known as protected cyber assets (PCAs).
NERC would submit responsive new or revised standards within 12 months of the effective date of a final rule.
With the FERC move, the question is how would these supply chain standards improve the grid.
“These OT, IoT, and ICS cyber-physical systems are mission-critical devices that are vital in maintaining the operation and availability of our critical infrastructure – including energy, water, oil/gas, solar, data centers,” said John Vecchi, security strategist at ICS/OT xIoT firm, Phosphorus Security. “Protecting them is less about improving the grid and more about maintaining their availability while preventing some kind of cyber-physical attack. Devices like mission-critical PLCs, HMIs, environmental sensors, robotics, and industrial gateways lack the most basic security hygiene yet are generally unknown, unmonitored, and unmanaged in these environments. And many of these assets have already been compromised by threat actors and nation-states.”
With the proposed standards, organizations would have to reassess their current risk management frameworks.
“Overall, risk management frameworks for critical infrastructure providers continues to be a challenge, with wide disparities between organizations and industries. But when it comes to protecting mission-critical cyber-physical systems, most all are in a terrible state of security,” Vecchi said. “This will take far more than just reassessing their current risk management frameworks, since most of those frameworks will not include even basic visibility of what OT/IoT assets they have, where they are located, and what critical vulnerabilities exist on them. Rather, there will need to be somewhat of a shift to view these critical yet vulnerable assets in the same way they view traditional IT assets and endpoints. This will require not only new technologies, but new policies and skill sets as well.”
As it is with changing rules and regulations, there are challenges for organizations.
“One of the biggest challenges critical infrastructure organizations will face with these kinds of new standards will be achieving even the most basic visibility of their mission critical OT, IoT, and ICS cyber-physical systems,” Vecchi said. “Today, most of these organizations would be hard-pressed to demonstrate visibility and inventory of these assets, let alone comprehensive risk assessment of their estates to know what is most vulnerable and what to prioritize for patching and remediation. Current state security tools do not provide the ability to safely and efficiently find, assess, fix, and monitor these critical systems. And given that these organizations simply cannot protect what they cannot see, this will be one of the most monumental challenges for most of them.”
In addition, FERC proposed to approve a CIP reliability standard that requires internal network security monitoring inside an entity’s electronic security perimeter, which NERC had submitted to comply with FERC Order No. 887.
That rule, approved in January 2023, directed NERC to develop CIP reliability standards requiring internal network security monitoring to provide greater defense-in-depth for entities’ CIP-networked environments.
FERC also is proposing to direct NERC to develop modifications to the internal network security monitoring standard to extend those protections outside of the electronic security perimeter to electronic access control or monitoring systems and physical access control systems. NERC would submit a responsive revised reliability standard within 12 months of the effective date of a final rule.