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Brent Castagnetto Manager, Cyber Security Audits

Brent Castagnetto Manager, Cyber Security Audits. Technical Feasibility Exception (TFE) Streamlining Proposal ERO-EMG May 5, 2012 Arlington, VA . TFE Streamlining Proposal. ERO Enterprise has nearly two years’ experience “in the field”. Based on that, we know:

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Brent Castagnetto Manager, Cyber Security Audits

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  1. Brent CastagnettoManager, Cyber Security Audits Technical Feasibility Exception (TFE) Streamlining Proposal ERO-EMG May 5, 2012 Arlington, VA

  2. TFE Streamlining Proposal • ERO Enterprise has nearly two years’ experience “in the field”. Based on that, we know: • Cost-to-benefit ratio of the process is skewed • CIP-based reliability and security can be monitored and promoted with less focus on lower-value administrative tasks currently required by Appendix 4D to the Rules of Procedure

  3. TFE Streamlining Proposal TFE Streamlining Proposal: • Eliminate the existing TFE process and perform compensating and/or mitigating control reviews at the time of Audit and/or Spot Check. • Utilize existing CMEP processes

  4. TFE Streamlining Proposal We request that NERC seek FERC acceptance of this proposal • MRO, Texas RE, WECC collaboration • ECEMG endorsed April 2012, requested REMG consideration • REMG endorsed April 2012, requested ERO-EMG consideration

  5. TFE History • TFE process was to be used as part of NERC’s phased approach. • TFEs were to be an interim step to augment Version 1 of the CIP Standards. • The TFE process would allow responsible entities a mechanism for requesting and receiving an exception from strict compliance. • We are four versions into CIP Standards; why do we still have Appendix 4D?

  6. MRO TFEs MRO has spent over 5,000 hours to process TFEs Part A, B, terminate, amend, report, audit review, etc. since 2009. • The hours include CIP audit team only.  693, Legal, and Reliability Assessment not included. • MRO estimatesits registered entities have used 20,000 hours managing TFEs (industry-only time) on TFEs since 2009.

  7. Texas RE TFEs Texas RE has spent over 2,000 hours to process TFEs.  • This includes CIP, 693, Legal, and Reliability Assessment Personnel. • Texas RE management notes the issue is the continued maintenance of a process that yields little benefit to reliability or security of the BES.

  8. WECC TFEs • WECC has received over2,400 TFE requests. • In 2011 WECC reviewed 968 TFE Part A requests, and 1198 TFE Part B requests. • WECC spent over 5,000 hours reviewing in 2011. • In 2010 WECC reviewed over 1200 Part and Part B TFEs. • WECC spent over 6000 hours in 2010.

  9. Other TFE Proposals CCWG has discussed several options: • “Option 1”: Unnecessary over-processing; length of time needed to revise Appendix 4D. • Option 2 and 3: Require revisions to standards-which will inevitably take years. • Option 4 was proposed by Texas RE, MRO and WECC and is presented here as the “TFE Streamlining Proposal” • Option 4 is supported by 6 of 8 regions in CCWG.

  10. TFE Streamlining Proposal • Repeal Appendix 4D to eliminate separate TFE processes and eliminate the term “TFE”. • Utilize Self Certification, Self Reports, Self Certifications and Spot Checks to validate and track compensating and mitigating measures. • Focus more on compensating measures and/or mitigating measures.

  11. Compensating/Mitigating Measures • CIP Standards already contain compensating/mitigating measures; if entities comply with these standards, they offer same protection as TFEs were intended to offer. • Some common examples of acceptable compensating and or mitigating measures include: • Cyber Assets reside within an ESP / PSP. (CIP-005 & CIP-006) • Cyber Security Training is required for all personnel with access to Cyber Assets. (CIP-004) • Personnel Risk Assessments are performed on personnel with access to Cyber Assets. (CIP-004)

  12. TFE Process Streamlining • Self Certification becomes the main vehicle for tracking compensating and mitigating measures. • Compensating and/or mitigating measures are required, and will be evaluated at Audit or Spot Check. • Outreach will be important.

  13. Education and Outreach • Provide guidance to Entities regarding self-evaluation of strict compliance and documentation of compensating and/or mitigating measures. • Regions will use effective CIP outreach programs prior to any compliance activity (Audit, Spot Check, Self Certification etc.)

  14. Benefits of TFE Streamlining Proposal • Refocus on risk-based reliability • More CIP resources available to focus on reliability and security rather than lower-value administrative tasks • Significant cost savings for Regional Entities and Responsible Entities

  15. Brent Castagnetto Manager, Cyber Security Audits WECC bcastagnetto@wecc.biz 801.819.7627 801.597.7957 Questions?

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