CIP-014 Implementation Update from NERC

On February 9, 2015, NERC posted an email regarding implementation of CIP-014-1, Physical Security.

In its email NERC offered three links to items of interest.  They included:

• "CIP-014 Memo to the Industry" from NERC
• "CIP-014-1, Requirement 1 Guidance" from the North American Transmission Forum (NATF)
• Link to the NERC Physical Security Standard Implementation website

And, for the reader's reference, here is the link to CIP-014-1.  Also, I wrote a blog about CIP-014 back on July 22, 2014.

CIP-014 Memo to Industry

The memo to the industry is from the NERC Compliance Assurance organization.  The specific focus of the memo is on CIP-14 Risk Assessment and Third-Party Verifications.  Notably the memo's purpose is to highlight acceptable approaches when implementing Requirements 1 and 2 of CIP-014.

Requirements 1 and 2 required Transmission Owners to perform a risk assessment and third-party verification process to identify Transmission stations and Transmission substations that will ultimately be subject to a physical security assessment (Requirement 4) and the implementation of subsequent physical security plan(s) (Requirement 5).

Per the CIP-014 implementation plans, each applicable Transmission Owner must perform its Requirement 1 risk assessment by October 1, 2015.

Then, within 90 days of completing the R1 risk assessment (i.e., by December 30, 2015) the Transmission owner must ensure that the third-party verifier completes the verification.

Within 60 days of completing the verification the Transmission Owner must either 1) modify its risk assessment to be consistent with the recommendations of the verifier, if any, or 2) document the technical basis for not modifying its risk assessment in accordance with any recommendations.

The memo does need to be read in its entirety; however, a key comment at the end that is probably most useful is that applicable Transmission Owners "...are expected to demonstrate effective application for NERC and the Regional Entities to be able to fully understand, for example:

• Why certain stations or substations are identified to meet the criteria in Requirement 1
• Similarly, why certain stations or substations were not identified by Requirement 1
• What are the defining characteristics of stations and substations identified by Requirement 1
• How the third-party verifying the risk assessment meets the qualifications in Requirement 2 and the mean the third party used to ensure effective verification."

North American Transmission Forum (NATF) Guideline

This document was prepared by the North American Transmission Forum (NATF) and issued on January 19, 2015.  The NATF is headquartered in Charlotte, NC and its members include investor-owned, state-authorized, municipal, cooperative, US federal, and Canadian provincial utilities.  The NATF "...promotes the highest levels of reliability in the operation of the electric transmission systems."

The intent of the document issued by NATF is to provide a general guideline for the risk assessment identified in R1 of CIP-014.  

The guideline offers five suggested steps for the Transmission Owner to follow to accomplish Requirement 1.  A high-level summary of the steps include:

• Step 1:  The Transmission Owner identifies stations to be analyzed based on criteria in CIP-014-1, Section 4.1.1
  
• Step 2:  The Transmission Owner identifies cases/system conditions to be analyzed.  Some cases could include -- summer vs winter peak load levels, shoulder peak load levels with system transfers, alternative generation dispatch assumptions or alternative load models.
  
• Step 3:  The Transmission Owner defines the nature of the initiating event and how it will be modeled in the transmission assessment
  
• Step 4:  The Transmission Owner is responsible for development of criteria/proxies for instability, uncontrolled separation or Cascading.
  
• Step 5:  The Transmission Owner performs appropriate steady-state power flow and/or stability analysis.

There are substantially more details provided under each step in the Guideline.

NERC Physical Security Web Page

A third link in the NERC announcement is for their Physical Security web page (a screenshot is shown below).

This page appears to be an excellent resource for those focused in CIP-014 implementation and compliance.

Conclusion

This blog does not offer adequate details on the contents of the referenced documents, therefore, taking time -- and having your power engineers taking time -- to read the CIP-014 requirements and the guidance from NERC and NATF will be worthwhile.

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FERC Requires Changes to NERC CIP-014 - Physical Security of Substations

On Thursday, July 17, 2014, the Federal Energy Regulatory Commission (FERC) published a Notice of Proposed Rulemaking (NOPR)  that proposed to approve CIP-014-1, Physical Security (PDF), with two modifications.

The NOPR did find that the proposed CIP-014-1 standard "...largely satisfies the directives in the (March 7, 2014 FERC) order.  However, the Commission proposes to direct NERC to develop a modification that would specifically allow governmental authorities, including FERC or another appropriate federal or provincial authority, to add or subtract facilities from an entity's list of critical facilities."

FERC does note in their announcement that they only expect the addition/subtraction of substations to be exercised only "rarely."

The second proposed modification from FERC directs NERC "...to revise wording that it believes could narrow the scope and number of identified critical facilities.  Specifically the NOPR seeks comment on the Commission's concern that NERC's use of the phrase 'widespread instability' rather than 'instability,' as stated in the March order, could create ambiguity since the term 'widespread' is not defined."

The NOPR also requests NERC submit two informational reports.  The first report would have NERC analyze whether CIP-014-1 should be applicable to additional types of facilities beyond substations.  The second report would have NERC provide analysis on grid resiliency exploring what can be done beyond CIP-014-1 to maintain reliable operation of the Bulk Power System when faced with the loss or degradation of critical facilities.

Crescendo of Activities Focused on Physical Security of Substations

In addition to the quick response by FERC when Pacific Gas & Electric's Metcalf substation was physically attacked in California on April 16, 2013, there have been several meetings and analyses produced examining how the industry should respond to physical attacks on critical substations.  For instance at the National Association of Regulatory Utility Commissioners (NARUC) summer meeting in Dallas on July 16, 2014, they passed a resolution on physical security of electric grid (PDF).

Overall, an excellent summary of the current situation regarding physical security concerns for the electric grid is the June 17, 2014 Congressional Research Service (CRS) report Physical Security of the U.S. Power Grid: High-Voltage Transformer Substations (PDF) .  This report is an encyclopedic review of the current state of physical security concerns and issues related to the larger transformers and substations.

A parenthetical observation from this report is on page 8 of the report regarding physical movement of the large transformers in an emergency.  The paragraph noted is cited below:

Within the United States, transportation of HV transformers is difficult. Due to their size and

weight, most HV transformers are transported on special railcars, each with up to 36 axles to

distribute the load. There are fewer than 20 of these railcars in the Unites States rated to carry 500 tons or more, which can present a logistical problem if they are needed in a transformer emergency. Some specialized flatbed trucks can also carry heavy transformer loads over public roadways, but the few such trucks that exist have less carrying capacity and greater route restrictions than the railcars because HV transformers may exceed highway weight limits.

Expect More Discussion in the Future

With the recent announcement from FERC, the very recent resolutions from NARUC, the tragic events associated with current wars in Europe and the Middle East, it would not surprise me if there are more conversations regarding the physical protection of the electric and gas grids.  

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Microgrids and Security -- More News...

For the past three days I've been attending and speaking at the 3rd Military and Commercial Microgrids Summit in Del Mar, California -- just north of San Diego.  I was invited to speak on a panel entitled "The Role of Microgrids in Military and Commercial Cyber Security" as a result of my article in Jesse Berst's Smart Grid News about this subject back in May.

Overall, this was a very interesting conference organized by Infocast that included a pre-summit technology showcase reviewing microgrid technologies followed by a day and a half summit.  There were approximately eight case studies, seven panel discussions, 11 presentations and over 115 registered attendees.  The topics ranged from microgrid controls and inverters through to commercializing and financing microgrids.  The next microgrid summit is slated for the U.S. East Coast in May 2014 and I'd highly recommend you consider attending due to its content and how well this recent conference was organized.

Now regarding security of microgrids -- the conference dialogue was very refreshing.  Of note, the first three presentations by San Diego Gas & Electric, PriceWaterhouseCoopers and IPERC highlighted the need to include cyber and physical controls in the microgrid deployments.  The IPERC presentation was especially interesting from a controls security perspective in that the microgrid controller communications they have developed are intended to be secure.

The best discussion regarding efforts to overtly include cybersecurity into microgrid deployments was the session on SPIDERS -- an effort paid by the US Department of Defense and led by Sandia National Labs.  As you can see in the graphic below from Sandia Labs, the SPIDERS effort includes four phases and cybersecurity is an intended foundation for these deployments at Joint Base Hickam, Hawaii; Fort Carson, Colorado; Camp Smith, Hawaii; and future deployments.

So, the good news is that I am not the lone voice in the forest worrying about microgrid security; however, it still has a long ways to go -- in my opinion -- before the security elements are built into the microgrid designs and deployments as a standard operating process.

So, what needs to be done?  Here are some ideas:

1)  Build a cybersecurity standard for microgrids that weaves in physical, IT, and Industrial Controls/OT security elements.  Perhaps an extension of NISTIR-7628, Guidelines for Smart Grid Cybersecurity, may be a good start.

2)  Leverage the work done by Sandia Labs in their Microgrid Cyber Security Reference Architecture.

3)  Establish some training modules on microgrid security -- perhaps this could be done under sponsorship of the Electric Power Research Institute (EPRI) or other similar organization to assure vendor neutrality.

It was obvious from the conference that we will be hearing more about microgrids in the future -- let's hope the news is about their cybersecurity resilience rather than weaknesses.

PS -- Happy Thanksgiving to my US readers!  Have a safe week!

Storm Photos - Our Infrastructure Under Duress

I just saw this slide show today including some interesting photos of post-storm damage and the important and courageous individuals who "fix" the problems.

Thanks to the public servants, utility workers and the volunteers who help restore our infrastructure back to "normal."

Have a good week, everyone and stay safe!

Most Fantastic Substation Photo!! Thanks EPRI!

The photo below was included in the Electric Power Research Institute's (EPRI) recent State of Technology | 2013 report.

The report is an excellent read about the state of the energy business and new technologies.  You can download the report here.

(By the way I worked at EPRI for about six years and enjoyed every minute of it!  EPRI is a top organization and provides so much to the industry.)