2Mandatory and Enforceable = V3 The WECC Cyber Security Audit Team will audit to Version 3 of the CIP Standards until such time as:Version 4 becomes mandatory & enforceable (10/1/14)FERC provides remand of V4, or approves V5NERC provides implementation plan guidance on V3 – V5 transitionThere will be opportunity to begin preparing for V5Slide used last month. Now NERC has the guidance so we are talking about it
3NERC Version 5 Transition Guidance On April 18th 2013 FERC issued a NOPR proposing to approve CIP V5Some changes were requested & NERC has respondedOn September 5th 2013 NERC provided revised guidance related to CIP Version 5Transition Period is from 9/5/2013 to V5 mandatory and enforceable date (still unknown)
4Version 4 / 5 UpdateOn 7/18/2013, the “Trade Associations” filed a motion to delay the deadline for complying with V4.FERC granted a six month extension on V4 to 10/1/2014.Logical conclusion that V5 will be approved before. Intel suggests approval sometime in Q4 of Tea leaves etc
5CIP Version 5 Transition Guidance “Prior to the date of mandatory enforcement of CIP Version 5, a Responsible Entity must continue to comply with the CIP Version 3 Standards (CIP through CIP-009-3) during the Transition Period”An entity may continue to maintain and apply its CIP RBAM during the transition period or it may choose one of two options to identify and document Critical Assets in lieu of maintaining a RBAM (R1) and applying (R2) its CIP RBAM.
6CIP Version 5 Transition Guidance On or after April 11th 2013, Registered Entities may choose:Option 1. Utilize the CIP Version 4 bright-line criteria in its entirety, with the exception of criterion 1.4 (Blackstart Resources) and criterion 1.5 (Cranking Paths), to identify assets subject to the controls in CIP through CIP-009-3, or
7CIP Version 5 Transition Guidance On or after September 5th 2013, Registered Entities may choose:Option 2. Utilize the CIP Version 5 “High” and “Medium” Impact Ratings (see CIP Attachment 1: IRC, pp ) to identify assets subject to the controls in CIP through CIP-009-3
8CIP Version 5 Transition Guidance Things to consider:Entities choosing option 1 or 2 as a valid Critical Asset Identification [CAID] methodology may decide to remove Critical Assets previously identified under a CIP RBAM.CIP Versions 4 and 5 contain requirements for asset identification that permit certain third parties to designate an asset as critical (Reliability Coordinators, Transmission Planners, Planning Coordinators, or Planning Authorities)
9CIP Version 5 Transition Guidance Things to consider:If option 1 (V4) is selected, be aware of Bright-Line Criteria 1.3, 1.8, 1.9, and 1.10If option 2 (V5) is selected, be aware of Impact Rating Criteria 2.3, 2.6 and 2.8
10CIP R3After the application of one of the two options to identify and document a list of Critical Assets, the entity must use the list of Critical Assets and apply its current CIP R3 Critical Cyber Asset Identification methodology [CCAID] to document a list of Critical Cyber Assets [CCAs] that are essential to the operation of the Critical Asset and meet one of the qualifying connectivity attributes (R3.1-R3.3).No change from the current CIP R3 process
11CIP R4The CIP Senior Manager must also review and approve the list of Critical Assets and the list of Critical Cyber Assets, even if such lists are null, at least annually (R4).The only change to R4 is annual review and approval of the RBAM will not be required if the entity has chosen option 1 or 2.
12CIP through CIP-009-3Based on the results of the application of the chosen CAID methodology, and subsequent application of the CCAID methodology to the list of Critical Assets, if the entity identifies a list of CCAs, the entity must continue to comply with all of CIP through CIPIf the list of CCAs is null, the entity must continue to comply with CIP R1-R4 (with the changes identified above) and CIP R2.
13CIP Version 5 Transition Guidance A Responsible Entity must identify the approach it is using for asset identification as part of its response to a pre-Compliance Audit Survey, a pre-Spot Check data request, or as otherwise requested pursuant to the Compliance Monitoring and Enforcement ProgramWECC will request information surrounding your approach in the audit / spot check notices in 2014A good practice to meet this data request is to have the CIP Senior Manager sign and date a statement declaring the entity’s choice of CAID methodology.
14CIP Version 5 Transition Guidance Within the Transition Guidance Document there is reference to the CIP Version 5 StudyThe study will collect and evaluate data from selected entities regarding implementation of CIP V5These results will be shared with industry upon completion of the study
15CIP Version 5 Transition Guidance What is the purpose of Transition Implementation Study?Determine compliance and enforcement expectations for the Industry during the transition from v3 to v5Determine technical challenges or compliance issues that limit the effective compliance to the CIP standardsImprove consistency, transparency and awareness of the newly approved CIP standards
17How will WECC Prepare for V5? WECC will provide significant outreach beginning at the September CIP-101 and throughout 2014 on the CIP Version 5 audit approach.Two Day outreach events will be held in various locations around the western interconnection to facilitate in person attendance.February 5-6 & MarchOpen webinar and CIPUG events will be used to advise WECC entities
18References References used in this presentation FERC Notice of Proposed Rulemaking (NOPR) on CIP Version 5Trade Associations RequestFERC Notice Granting Extension Of TimeNERC V5 Transition Guidance
19WECC CIP-002 Subject Matter Experts Dr. Joe Baugh(M)(O)Bryan Carr(O) (M)