I have posted recently on the need to rewrite two NERC CIP requirements: CIP-007 Requirement R2 (patch management) and CIP-010 Requirement R1 (configuration management). The primary reason that both requirements need to be rewritten is that they are by far the most prescriptive CIP requirements. In fact, since CIP version 5 (when both these requirements were substantially revised) came into effect in 2016, I have heard that complying with just these two requirements accounts for a substantial percentage of all NERC compliance costs, not just NERC CIP compliance costs.
However, the second reason why these two requirements need to be rewritten is that they are currently the two biggest barriers to use of the cloud by NERC entities with medium or high impact BES environments. The main reason for this is that the two requirements apply on the level of individual BES Cyber Assets, even though they’re written to apply to BES Cyber Systems (BCS). This means that a cloud service provider would have to produce documentation for the NERC entity that showed the CSP had taken every required step in CIP-007 R2 and CIP-010 R1 for every device on which any part of the BCS resided during the audit period.
One of the main reasons why use of the cloud is so inexpensive is that systems (i.e., the software and data in systems) can be moved from server to server and datacenter to datacenter whenever it’s advantageous to do so. It would be hugely expensive if a CSP were required to provide that information, and it’s doubtful that any CSP would even entertain the idea of doing that. None of the other CIP requirements require providing documentation at anywhere near that level of detail.
Fortunately, both the prescriptiveness problem and the cloud documentation problem can be cured with the same medicine: rewriting CIP-007 R2 and CIP-010 R1 to make them “objectives-based” (that is NERC’s term, although mine is “risk-based”. They mean effectively the same thing). When will that happen?
Last summer, a new NERC Standards Drafting Team started working on what will undoubtedly be a huge multi-year project to revise (and/or add to) the existing NERC CIP standards to make them “cloud-friendly”. They haven’t worked out their agenda yet, but I recently estimated that the new and/or revised standards will be fully approved and enforced around 2031. This is based on the experience with CIP version 5, which took almost that long and which in some ways was easier to draft than “cloud CIP” will be.
However, one thing is certain about the SDT’s agenda: it will include rewriting CIP-007 R2 and CIP-010 R1. Given how controversial both requirements are, and the fact that CIP-007 R2 needs to be rewritten as a vulnerability management, not a patch management, requirement, I think just rewriting and balloting those two requirements will take 1 ½ to 2 years. While this work will undoubtedly require some coordination with the “Risk Management for Third-Party Cloud Services” drafting team, this is something that NERC drafting teams do all the time.
So here’s my idea: Why not create a new Standards Authorization Request (SAR) that just requires rewriting the two requirements? This would take CIP-007 R2 and CIP-010 R1 completely off the cloud SDT’s plate, meaning they might be able to finish their work in five years, not seven. And it would allow the two revised requirements to be drafted by a fresh team that’s excited about being able to fix the two biggest “problem children” among the NERC CIP requirements, rather than a team that’s midway through a 7-year slog and wondering if perhaps long-distance truck driving would have been a better career choice.
While I would technically be allowed to draft that SAR, I don’t have the time to do it – and more importantly, a SAR has much better chance of approval if it’s prepared by one or two NERC entities (with perhaps a vendor also participating). However, if a NERC entity wants to take the lead on this, I’d be pleased to help draft it.
Any opinions expressed in this blog post are strictly mine and are not necessarily shared by any of the clients of Tom Alrich LLC. 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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