CIP standards may not be enough to secure electric grid
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Industry and government regulators have begun putting some teeth into mandatory reliability standards for critical infrastructure protection of the nation’s power grid, but some observers say security controls might not be adequate for today’s interconnected networks.
Industry regulators have begun compliance audits this month on mandatory reliability standards for the nation’s bulk electric power distribution system, a step toward implementing critical infrastructure protection standards for the U.S. power grid.
“It’s a big step,” said Joe McClelland, director of the Office of Electric Reliability at the Federal Energy Regulatory Commission. “It’s the first time they’ll have a critical infrastructure protection standard.”
As the power grid becomes more automated and its control systems networked on a large scale, the system's cybersecurity is becoming a critical issue. The security standards for the system require that operators identify critical cyber assets that support reliable operation of the electric system, using a risk-based assessment. Violators can be fined as much as $1 million a day.
But some security experts say the standards do not go far enough. The technology of the electric grid was designed with the expectation that it would be a private network rather than an interconnected IP-addressable system, and the security standards focus largely on reliability rather than network integrity.
“I don’t think in today’s world that is even close to being adequate security,” said Jack Danahy, chief technology officer of Ounce Labs. “There has to be a more expansive understanding of what security means.”
The cybersecurity of the power distribution system is taking on more urgency with development of a new interactive smart grid and recent reports that hackers have compromised the current grid.
FERC is the government overseer of the U.S. power grid under the Energy Policy Act of 2005, but the audits are carried out by the North American Electric Reliability Corp., the industry’s designated international self-regulatory authority. Despite FERC’s authority, there is still a high degree of self-regulation in the power system. NERC developed the security standards, which FERC can approve or reject.
FERC approved the current Critical Infrastructure Protection Standards this year. FERC will review the audit results and take part in a number of them. “Not every audit,” McClelland said. “Just to check to see how they are being conducted.”
If NERC finds violations, it can propose penalties to FERC, and violators can appeal those penalties with FERC. In addition to its appellate role, FERC can also take part in NERC investigations and conduct investigations on its own, but those activities would be rare, McClelland said.
The standards apply to the bulk power system, which is identified as generation and transmission facilities handling power at 100,000 volts or more.
The physical power grid and its control systems are designed to be robust and resilient, able to withstand failures of multiple elements without interrupting the power load or causing instability. FERC and NERC are aware that cybersecurity goes beyond reliability.
“As we consider cybersecurity, a host of new considerations arise,” NERC Chief Security Officer Michael Assante said in an April 7 letter to industry stakeholders. “Rather than considering the unexpected failure of a digital protection and control device within a substation, for example, system planners and operators will need to consider the potential for the simultaneous manipulation of all devices in the substation, or, worse yet, across multiple substations.”
The threat could include not just a failure or disruption of controls or services, but their deliberate misuse as well, he said. However, in a self-certification industry compliance survey for the last half of 2008, a surprisingly large number of companies and operators reported having no critical assets that fall under the Critical Infrastructure Protection Standards. This could mean that security controls are not being implemented on portions of the grid.
At least two bills have been introduced in the House to revamp security regulation of the nation’s power grid. The bills could expand federal regulation beyond the present bulk power system as well as enhance research on security threats to the system.
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