Electric Grid Cybersecurity Updated September 4 2018 Congressional Research Service https crsreports congress gov R45312 Electric Grid Cybersecurity Summary Electricity generation is vital to the commerce and daily functioning of the United States The U S electric power grid comprises all of the power plants generating electricity together with the transmission and distribution lines and systems that bring power to end-use customers The U S electric grid has operated historically with a high level of reliability however the various parts of the electric power system are all vulnerable to failure due to natural operational or manmade events The bulk power system faces new and evolving cybersecurity threats Cyber threats can come from direct attacks aimed at electric grid or other critical infrastructure that could impact the operations or security of the grid Arguably the greatest cyber threats to the grid have been intrusions focused on manipulating industrial control system ICS networks Cyber intrusions on the electric grid have resulted in malware on ICS networks with the capability of causing damage or taking over certain aspects of system control or functionality Recent concerns have extended to Internet of Things IoT devices connected to networks IoT devices have been increasingly targeted by botnet malware whereby the hacker takes over the operation of a large number of infected devices to launch denial-of-service or other cyberattacks If such IoT cyberattacks were able to access electric utility ICS networks they could potentially impair these systems or cause electric power networks to operate based on manipulated conditions or false information Congress gave the Federal Energy Regulatory Commission FERC authority to oversee the reliability of the bulk power system under the Energy Policy Act of 2005 P L 109-58 EPACT05 FERC can approve or remand back reliability standards proposed by the Electric Reliability Organization ERO which bulk-power system owners and operators must follow to help ensure the reliable operation of the grid The North American Electric Reliability Corporation serves currently as the ERO and proposes mandatory and enforceable reliability standards for Critical Infrastructure Protection which include physical and cybersecurity There have been increasing reports about foreign hackers targeting the U S electric power system and other critical infrastructure While these intrusions have not been reported as having resulted in significant disruptions concerns have increased over the potential of the intrusions for potentially damaging cyberattacks In 2017 the President issued Executive Order EO 13800 on “Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure” because the risks of cyber threats to critical infrastructure are perceived as a national security imperative EO 13800 called for an assessment of a prolonged electric power outage resulting from a cyberattack and an evaluation of the “readiness and gaps in the United States’ ability to manage and mitigate consequences of a cyber incident against the electricity subsector ” The cyber supply chain and public-private cybersecurity information sharing were listed among a number of major cybersecurity concerns Electricity is a subsector of the energy critical infrastructure CI sector Given that the grid relies on several of the other CI sectors for example water and fuel transportation the question of whether these other sectors should also have similar mandatory standards focused on support of the electric power sector may be an issue for Congress to consider The electric power system in the United States is evolving but not consistently across sectors and regions of the country While some may say such inconsistencies may add a level of complexity that may make a nationwide cyber event more unlikely the consistent development of a modern electric power system would likely add to the prospects of U S economic health and competitiveness Policy options designed to ensure that the developing electric power system is as secure as possible will likely be a major consideration for Congress Congressional Research Service Electric Grid Cybersecurity Contents Introduction 1 Electric Grid Reliability 2 Some Recent Developments in Grid Cyber Policy 4 Presidential Executive Order 13800 4 Department of Energy Establishes New Cybersecurity Office 4 Revised Voluntary Cybersecurity Framework 5 Cyber and Physical Security of the Grid 5 Critical Infrastructure Protection Standards 7 Grid Security Exercises 8 Cyber Threats to the Grid 8 Industrial Control System Vulnerabilities 9 Some Recent Malware Threats 9 Potential Cyber Threat to Grid from the Internet of Things 11 Supply Chain Risks 11 Other Grid Cybersecurity Issues 13 Operation Technology OT Systems 13 Human Factor in Cybersecurity 14 Electric Power Cybersecurity Gaps 14 Mutual Dependency of Critical Infrastructure 15 Artificial Intelligence for Cybersecurity 15 Artificial Intelligence 15 Data Analytics 16 Risks with AI and Machine Learning 16 Improving Grid Cybersecurity 17 Increasing Cyber Monitoring and Incident Reporting 18 FERC Increasing Reporting of Cyber Incidents 19 Mandatory DOE Reporting of Grid Incidents and Disturbances 19 Enhancing the Threat Risk Assessment 20 Building Resiliency into the Grid 21 Building the Smart Grid 21 Distributed Energy Resources 22 Building a Strategic Reserve of Critical Components 23 Other Issues for Congress 23 Recent Legislation 24 115th Congress 24 Tables Table A-1 NERC Critical Infrastructure Protection Standards 25 Congressional Research Service Electric Grid Cybersecurity Appendixes Appendix Bulk Electric System Critical Infrastructure Protection Standards 25 Contacts Author Information 26 Congressional Research Service Electric Grid Cybersecurity Introduction Electricity generation is vital to the commerce and daily functioning of the United States The electric power grid in the United States comprises all of the power plants generating electricity together with the transmission and distribution lines and systems which bring power to end-use customers The grid also connects the many publicly and privately owned electric utility and other wholesale power companies in different states and regions of the United States The U S electric grid has historically operated with a high level of reliability however the various parts of the electric power system are all vulnerable to failure due to natural operational or manmade events While natural and operational failures can be mitigated somewhat by planning and prudent investments cybersecurity is a growing concern for both electric utilities and other critical infrastructure entities Adoption of digital technologies has improved the efficiency and speed of operations and processes and allowed for an almost instantaneous exchange of information between connected devices Often these digital devices are also connected to the internet to increase the ability to share information with a multitude of users and devices While the benefits of internet-connected digital technologies are many so too are the risks of a cybersecurity breach from exposure to a globally internet-connected environment The electric grid relies on a number of electronic devices switches and circuit breakers to regulate and report on the flow of electricity at different parts of the system Together these pieces of mechanical and automated equipment constitute the grid’s industrial control system ICS network managing power plant controls transformer yard and power bus functions transmission and distribution substations The grid’s ICS networks essentially operate in a “control loop” in which sensors continually check key components with variable responses against control variables to ensure that the system is functioning as designed ICS networks control industrial processes in a number of energy and manufacturing operations One particular type of ICS network common in the electric power industry is a supervisory control and data acquisition SCADA system which gathers information from remote stations across a utility system to control geographically dispersed assets In 2015 a cyberattack on distribution utility substations in Ukraine shut off power to over 225 000 utility customers for several hours and was the first time that a cyberattack was publicly acknowledged to have caused a grid power outage 1 A second cyberattack in Ukraine in 2016 was reported on an electricity control center in the city of Kiev shutting down substations which controlled 200 megawatts of capacity The potential for a similar attack on the U S grid was seen as a possibility 2 Some recent reports about foreign hackers targeting the U S electric power system and other critical infrastructure are summarized below While these intrusions have not been reported as having resulted in significant disruptions concerns have increased over the potential for these intrusions to result in damaging cyberattacks in the future 3 The intrusions which have been 1 Electricity Information Sharing and Analysis Center Analysis of the Cyber Attack on the Ukrainian Power Grid March 18 2016 https www nerc com pa CI ESISAC Documents E-ISAC_SANS_Ukraine_DUC_18Mar2016 pdf 2 John Condliffe Ukraine’s Power Grid Gets Hacked Again a Worrying Sign for Infrastructure Attacks MIT Technology Review December 22 2016 https www technologyreview com s 603262 ukraines-power-grid-getshacked-again-a-worrying-sign-for-infrastructure-attacks 3 Robert Walton U S Sounds Alarm over Increased Cyber Threat to Energy Other Sectors UtilityDive October 24 2017 https www utilitydive com news us-sounds-alarm-over-increased-cyber-threat-to-energy-other-sectors 507987 Congressional Research Service R45312 · VERSION 2 · UPDATED 1 Electric Grid Cybersecurity directed at the ICS networks of energy manufacturing communications and nuclear entities include the following Cyber intrusions on the SCADA systems of the Bowman Dam in Rye NY resulted in federal indictments against a group of hackers linked to Iran’s Islamic Revolutionary Guard Corps 4 Cyber intrusions in October 2017 were reported to have targeted electric company ICS networks in a reconnaissance and information gathering campaign attributed to North Korea 5 In March 2018 the United States Computer Emergency Readiness Team USCERT issued an alert concerning cyber intrusions at critical energy and manufacturing infrastructure companies The Department of Homeland Security and the Federal Bureau of Investigation concluded that Russian government hackers conducted a multistage intrusion campaign to access files on ICS networks The malware conducted network reconnaissance collecting information on ICS and SCADA systems before being found 6 Further attacks on U S critical energy infrastructure are expected as nation states view disruption of the U S economy as a potential target 7 This report discusses the current state of electric grid cybersecurity and the interconnected dependency of critical infrastructure with regard to electric sector reliability Current efforts to ensure the reliability of the grid are highlighted and potential grid vulnerabilities are explored with a focus on the electric power sector’s mutual dependency on other critical infrastructure Technologies and actions to address perceived future threats are described and possible risks to approaches moored in technology-based cybersecurity defense systems Finally since the possibility does exist for a major cyber and or physical security attack to result in significant damage or impairment the potential need to build resilience into the grid to enable a quicker recovery is discussed Electric Grid Reliability Congress gave the Federal Energy Regulatory Commission FERC authority to oversee the reliability of the bulk-power system under the Energy Policy Act of 2005 P L 109-58 EPACT05 Reliability standards were added as Section 215 of the Federal Power Act FPA in an effort to help ensure the reliable operation of the bulk power system so that “instability U S Department of Justice “Manhattan U S Attorney Announces Charges Against Seven Iranians for Conducting Coordinated Campaign of Cyber Attacks Against U S Financial Sector on Behalf of Islamic Revolutionary Guard Corps-Sponsored Entities ” press release March 24 2016 https www justice gov usao-sdny pr manhattan-usattorney-announces-charges-against-seven-iranians-conducting-coordinated 5 Chris Bing Hackers Linked to North Korea Targeted U S ICS Companies Breached Energy Firm Cyberscoop October 10 2017 https www cyberscoop com north-korea-ics-hacking-dhs-ics-cert 6 U S Computer Emergency Readiness Team Russian Government Cyber Activity Targeting Energy and Other Critical Infrastructure Sectors Alert TA18-074A March 15 2018 https www us-cert gov ncas alerts TA18-074A 7 Director of National Intelligence Daniel Coats warned that the U S should brace for “localized and temporary disruptions of critical infrastructure ” observing that the proliferation of digital devices and newly “emboldened and better equipped” adversaries may resort to damaging cyber operations in geopolitical crises that fall short of war The assessment singled out Russia China Iran and North Korea as posing the biggest cyberthreats to the United States Daniel R Coats Worldwide Threat Assessment Statement for the Record February 13 2018 https www dni gov files documents Newsroom Testimonies 2018-ATA---Unclassified-SSCI pdf 4 Congressional Research Service R45312 · VERSION 2 · UPDATED 2 Electric Grid Cybersecurity uncontrolled separation or cascading failures” will not occur as a result of a sudden disturbance 8 Section 215 of the FPA also defines FERC’s jurisdiction in terms of “users owners and operators” of the bulk power system 9 FERC can approve or remand back reliability standards proposed by the Electric Reliability Organization ERO which bulk-power system owners and operators must follow to help ensure the reliable operation of the grid Currently the North American Electric Reliability Corporation NERC serves as the ERO NERC therefore proposes reliability standards for Critical Infrastructure Protection CIP which are updated considering the status of reliability and cybersecurity concerns for the grid Reliability standards address programs ranging from vegetation clearances in electric transmission line rights-of-way to policies and procedures for critical infrastructure protection focused on the cyber- and physical security of power plants and supporting facilities The standards are both mandatory and enforceable in that violators of reliability rules may be subject to a civil fine of up to $1 million per violation for each day that it continues While the bulk electric power system has mandatory and enforceable standards for both cyber and physical security for critical infrastructure protection these are developed on a consensus basis before being submitted to FERC which determines whether to accept or remand the standard back to NERC for revision Under the Federal Power Act FERC’s authority is largely limited to wholesale power sales and the transmission of electricity in interstate commerce while states have authority over retail sales by electric distribution systems FERC acknowledges that EPACT05 excluded local distribution systems from its reliability mandate under Section 215 of the Federal Power Act as not being part of the bulk power system That criterion excluded facilities in Alaska and Hawaii and virtually the entire grid in cities with large distribution systems like New York City In 2012 FERC approved NERC’s criteria for the definition of the bulk electric system 10 These criteria and definitions apply to all NERC regions and are a bright-line threshold including all Transmission Elements operated at 100 kilovolts kV or higher and real power11 and reactive power12 resources connected at 100 kV or higher 13 8 Reliability according to the U S Department of Energy is the ability of the system or its components to withstand instability uncontrolled events cascading failures or unanticipated loss of system components See https www energy gov sites prod files 2017 01 f34 Chapter%20IV%20Ensuring%20Electricity%20System%20Reliab ility%2C%20Security%2C%20and%20Resilience pdf 9 FERC Order No 773 establishes a “bright-line” threshold essentially considering all transmission facilities and related facilities operating at 100 kiloVolts or above to be part of the bulk electric power system As such these facilities are subject to the applicable NERC reliability standards 10 See 139 FERC 61 247 11 Real or active power is the “component of electric power that performs work typically measured in kilowatts kW or megawatts MW ” See http www eia gov tools glossary index cfm 12 Reactive power is the “portion of electricity that establishes and sustains the electric and magnetic fields of alternating-current equipment Reactive power must be supplied to most types of magnetic equipment such as motors and transformers Reactive power is provided by generators synchronous condensers or electrostatic equipment such as capacitors and directly influences electric system voltage It is a derived value equal to the vector difference between the apparent power and the real power It is usually expressed as kilovolt-amperes reactive KVAR or megavoltampere reactive MVAR ” See http www eia gov tools glossary index cfm 13 The discussion of bulk electric system “Transmission Elements” begins with a general definition These are “ a ny electrical device with terminals that may be connected to other electrical devices such as a generator transformer circuit breaker bus section or transmission line An element may be comprised of one or more components ” North American Electric Reliability Corporation Bulk Electric System Definition Reference Document Version 2 April 2014 p 5 https www nerc com pa RAPA BES%20DL bes_phase2_reference_document_20140325_final_clean pdf Congressional Research Service R45312 · VERSION 2 · UPDATED 3 Electric Grid Cybersecurity Some Recent Developments in Grid Cyber Policy The increase in the number of cyberattacks aimed at U S critical energy infrastructure has led to heightened attention from the federal government 14 While a cyberattack on the U S grid similar to the cyberattacks in Ukraine was not expected to result in the same type of consequences given the older electricity systems in place in Ukraine the potential for financial market and economic disruption may be a legitimate concern Presidential Executive Order 13800 In 2017 President Trump issued Executive Order E O 13800 on “Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure” because the risks of cyber threats to critical infrastructure are perceived as a national security imperative 15 E O 13800 called for an assessment of a prolonged electric power outage resulting from a cyberattack and an evaluation of the “readiness and gaps in the United States’ ability to manage and mitigate consequences of a cyber incident against the electric subsector ” The cyber supply chain and public-private cybersecurity information sharing were listed among a number of major cybersecurity potential vulnerabilities Department of Energy Establishes New Cybersecurity Office The Fixing America’s Surface Transportation Act FAST Act P L 114-94 gives the Department of Energy DOE new authority to order electric utilities and NERC to implement emergency security actions 16 DOE is designated as the lead sector-specific agency for the Energy sector with responsibilities for both physical and cybersecurity 17 DOE has established a new Office of Cybersecurity Energy Security and Emergency Response CESER to “bolster DOE’s efforts in cybersecurity and energy security ”18 CESER is to focus on more coordinated preparedness and response to natural and man-made threats to energy infrastructure security Following E O 13800 DOE established a five-year strategy for reducing cyber risks in the U S energy sector which is intended to serve as the basis for CESER activities Under the strategy 14 Rebecca Kern Utilities Prepare for Increased Cyberattacks on the Electric Grid Bloomberg Environment and Enviroment Report August 7 2018 https www bna com utilities-prepare-increased-n73014481471 15 Executive Order 13800 “Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure ” 82 Federal Register 22391 16 Section 61003 of FAST creates a new Section 215A of the Federal Power Act that following a written determination by the President authorizes DOE to order utilities the North American Electric Reliability Corporation NERC and Regional Entities to implement emergency security measures for up to 15 days at a time 17 The energy sector is one of 16 critical infrastructure sectors identified in Presidential Policy Directive-21 Critical Infrastructure Security and Resilience Sector specific agencies are designated with specialized expertise in those critical infrastructure sectors that are tasked with various roles and responsibilities for their respective sectors as specified in PPD-21 i e development of sector-specific plans coordination with the Department of Homeland Security and incident management responsibilities 18 DOE Secretary of Energy Rick Perry Forms New Office of Cybersecurity Energy Security and Emergency Response February 14 2018 https www energy gov articles secretary-energy-rick-perry-forms-new-officecybersecurity-energy-security-and-emergency Congressional Research Service R45312 · VERSION 2 · UPDATED 4 Electric Grid Cybersecurity CESER will carry out the DOE’s Office of Electricity’s cybersecurity responsibilities in supporting the physical and cybersecurity needs of energy owners and operators 19 Three main goals have been established under the strategy Strengthen Energy Sector Cybersecurity Preparedness—focuses efforts through Cybersecurity Risk Information Sharing Program CRISP activities 20 Coordinate Cyber Incident Response and Recovery—establishes a coordinated national cyber incident response capability for the energy sector to augment cyber mutual assistance DOE’s national laboratories are to develop an integrated set of specialized cyber resources and capabilities that can be deployed to help energy companies identify and respond to a cyberattack and Accelerate Game-Changing Research Development and Demonstration RD D of Resilient Energy Delivery Systems—keys on research development and demonstration of new cybersecurity tools and technologies for automated defense of future energy delivery systems Revised Voluntary Cybersecurity Framework While the bulk electric system has mandatory and enforceable rules for cyber and physical security other energy sectors do not In April 2018 the National Institute of Standards and Technology NIST released its revised voluntary Cybersecurity Framework The framework is a risk-based approach to cybersecurity that is generally applicable to industries using a range of IT technologies including Internet of Things IoT devices The Framework focuses on “using business drivers to guide cybersecurity activities and considering cybersecurity risks as part of the organization’s risk management processes ”21 Cyber and Physical Security of the Grid The energy sector is one of 16 infrastructure sectors designated as critical infrastructure by Presidential Policy Directive-21 PPD-21 22 The stated goal of PPD-21 is to advance “a national unity of effort to strengthen and maintain secure functioning and resilient critical infrastructure ” The energy sector under the policy directive includes electricity oil and natural gas The reliance of virtually all industries on electric power is recognized by the U S Department of Homeland Security DHS which has the primary responsibility for implementing PPD-21 23 19 DOE Multiyear Plan for Energy Sector Cybersecurity March 2018 https www energy gov sites prod files 2018 05 f51 DOE%20Multiyear%20Plan%20for%20Energy%20Sector%20Cybersecurity%20_0 pdf 20 CRISP provides energy sector owners and operators with a capability to voluntarily share cyber threat data in nearreal-time analyze this data using U S intelligence and receive machine-to-machine threat alerts and mitigation measures 21 National Institute of Standards and Technology Framework for Improving Critical Infrastructure Cybersecurity Version 1 1 April 16 2018 https nvlpubs nist gov nistpubs CSWP NIST CSWP 04162018 pdf 22 See Presidential Policy Directive-21 PPD-21 Critical Infrastructure Security and Resilience at https obamawhitehouse archives gov the-press-office 2013 02 12 presidential-policy-directive-critical-infrastructuresecurity-and-resil 23 “There are 16 critical infrastructure sectors whose assets systems and networks whether physical or virtual are considered so vital to the United States that their incapacitation or destruction would have a debilitating effect on security national economic security national public health or safety or any combination thereof ” DHS Critical Infrastructure Sectors 2018 https www dhs gov critical-infrastructure-sectors Congressional Research Service R45312 · VERSION 2 · UPDATED 5 Electric Grid Cybersecurity A report released by the National Research Council NRC in 2012 recognized the vulnerability of the electric power delivery system to either cyber and or physical attacks The NRC report concluded that well-informed terrorists could black out a large region of the country for weeks or even months 24 An event of this magnitude and duration could lead to turmoil widespread public fear and an image of helplessness that would play directly into the hands of the terrorists If such large extended outages were to occur during times of extreme weather they could also result in hundreds or even thousands of deaths due to heat stress or extended exposure to extreme cold The largest power system disruptions experienced to date in the United States have caused high economic impacts Considering that a systematically designed and executed terrorist attack could cause disruptions that were even more widespread and of longer duration it is no stretch of the imagination to think that such attacks could entail costs of hundreds of billions of dollars—that is perhaps as much as a few percent of the U S gross domestic product GDP which is currently about $12 5 trillion 25 The NRC report further commented on the potential effects of a combined cyber and physical attack on the grid If they could gain access hackers could manipulate SCADA systems to disrupt the flow of electricity transmit erroneous signals to operators block the flow of vital information or disable protective systems Cyber attacks are unlikely to cause extended outages but if well coordinated they could magnify the damage of a physical attack For example a cascading outage would be aggravated if operators did not get the information to learn that it had started or if protective devices were disabled 26 Similar conclusions were reached in a 2015 report from the University of Cambridge and Lloyds of London which stated that a targeted cyberattack could leave 15 states and 93 million people from New York City to Washington DC without power The scenario estimated the total impact to the U S economy at between $243 billion and $1 trillion resulting from “direct damage to assets and infrastructure decline in sales revenue to electricity supply companies loss of sales revenue to business and disruption to the supply chain ”27 The 2013 attack on the Metcalf substation in California further cast light on the physical vulnerabilities of the grid After someone broke into a nearby underground vault to cut telephone cables snipers opened fire on the substation knocking out 17 large power transformers sending power to Silicon Valley A blackout was averted by rerouting power around the substation and local power plants were called upon to produce more electricity It took the local utility 27 days to restore the substation The Federal Energy Regulatory Commission’s FERC’s chairman at the time reportedly said that “if the attack were widely replicated across the country it could take down the U S electric grid and black out much of the country ”28 Largely as a result of the grid 24 National Academy of Sciences Terrorism and the Electric Power Delivery System 2012 http www nap edu catalog 12050 terrorism-and-the-electric-power-delivery-system 25 Ibid p 1 26 Ibid p 2 27 University of Cambridge Centre for Risk Studies and Lloyds of London Business Blackout The Insurance Implications of a Cyberattack on the US Power Grid 2015 https www lloyds com media files news%20and%20insight risk%20insight 2015 business%20blackout business%20blackout20150708 pdf 28 Rebecca Smith “Assault on California Power Station Raises Alarm on Potential for Terrorism ” Wall Street Journal February 5 2014 http www wsj com articles SB10001424052702304851104579359141941621778 Congressional Research Service R45312 · VERSION 2 · UPDATED 6 Electric Grid Cybersecurity vulnerabilities highlighted by this incident FERC directed NERC to develop a physical security standard which culminated in CIP-014 29 Since the 2015 cyberattack in Ukraine some have expressed increased concerns over the cybersecurity of interconnected U S electric power systems The 2015 Ukraine cyberattack and blackouts demonstrated that an electric grid could be infiltrated controlled and rendered inoperable through internet-connected systems by an outside unauthorized entity Recovery from a well-planned cyber and physical attack on the grid could be complicated by the cost and vulnerability of critical components While a physical attack on transmission towers to bring down power lines could cause blackouts the strategic destruction of a number of critical high-voltage transformers could potentially cause long-lasting power outages These transformers are large and difficult to move A large-scale attack may use up the limited inventory of spare units 30 and it may take months or years to build new units due mainly to the size and often unique specifications of high-voltage transformers The availability of other large components such as high-voltage circuit breakers could also hamper recovery efforts 31 The security of the supply chain for grid devices and components is discussed later in this report Critical Infrastructure Protection Standards NERC has a set of mandatory and enforceable standards for electricity reliability to protect the critical infrastructure of the bulk electric system BES NERC periodically updates the applicable version of the critical infrastructure protection cybersecurity CIP standards which leads to a new compliance phase for the owners and operators of the BES The current iteration of NERC’s standards is CIP Version 6 which contains several updates to Version 5 requirements largely reflecting increased security for BES assets and training for utility personnel 32 Table A-1 in the Appendix of this report lists the current standards in effect and several standards pending regulatory approval from FERC NERC’s CIP Version 5 moved utility companies toward active planning for system security needs rather than solely compliance with the standards It established criteria mandating that BES owner operators focus on improving the security of critical assets 33 BES assets were categorized as low or high impact and were to be protected according to the level of requirements for that impact category CIP Version 5 also required encryption of grid command and control signals “role-based” instead of “risk-based” classifications requiring multiple levels of compliance considering facilities with low- medium- or high-level potential impacts on the BES monitoring See the Appendix Table A-1 “NERC Critical Infrastructure Protection Standards ” The electric power industry has several programs for participating companies to share spare transformer equipment For example “ the Edison Electric Institute’s Spare Transformer Equipment Program requires participating utilities to maintain or acquire a specific number of transformers up to 500 kV to be made available to other utilities in case of a critical substation failure Sharing of transformers is mandatory based on a binding contract subject to a ‘triggering event’—a coordinated act of deliberate documented terrorism resulting in the destruction or disabling of a transmission substation and the declaration of a state of emergency by the President and in 2012 NERC initiated its Spare Equipment Database program intended to serve as a tool to ‘facilitate timely communications between those needing long-lead time equipment damaged in a high impact low frequency event and those equipment owners who may be able to share existing equipment being held as spares by their organization ’” See CRS Report R43604 Physical Security of the U S Power Grid High-Voltage Transformer Substations by Paul W Parfomak 31 National Academy of Sciences Terrorism and the Electric Power Delivery System 2012 http www nap edu catalog 12050 terrorism-and-the-electric-power-delivery-system 32 NERC CIP Standards 2017 https www nerc com pa Stand Pages CIPStandards aspx 33 NERC CIP Version 5 went into effect in July 2015 29 30 Congressional Research Service R45312 · VERSION 2 · UPDATED 7 Electric Grid Cybersecurity and control of remote access internet connections with inclusion of serial connections multiplefactor authentication rather than a one-step password for access incident response recovery plans physical security of BES cyber assets to prevent unauthorized physical entry and access and cataloging of all software and all security patches on BES devices Grid Security Exercises Every two years the North American Electric Reliability Corporation NERC organizes a twoday grid security exercise called GridEx to test the electricity sector’s ability to respond to grid security emergencies caused by cyber and physical attacks The goals of GridEx include the determination of ways to best secure the grid and improve future response by improving communications among companies and state and federal agencies identifying lessons learned and engaging senior company leadership The 2017 GridEx drill was the fourth iteration of the exercise and had over 6 500 participants from the United States Canada and Mexico 34 NERC released its public report of the results of GridEx IV drill listing lessons learned and recommendations to enhance grid security Recommendations in the report included increasing coordination between utilities and federal state and local governments enhancing information sharing capabilities for the Electricity Subsector Coordinating Council ESCC and Energy Government Coordinating Council developing ESCC processes for emergency orders and continuing to promote the Cyber Mutual Assistance Program 35 A focus on recovery from a potential large-scale physical or cyberattack appears to be an increasing part of the exercises The Cyber Mutual Assistance CMA program is intended to provide a pool of utility cybersecurity experts who can share their expertise with other utilities in the event of a disruption of electric or natural gas service systems and or IT infrastructure due to a cyber emergency NERC recommended that more utilities should participate in the CMA program Additionally NERC proposed that the ESCC and the Electricity Information Sharing and Analysis Center E-ISAC also increase their participation in the CMA program to encourage the efficient sharing of relevant information 36 Cyber Threats to the Grid The bulk power system faces new and evolving cybersecurity threats on a daily basis Cyber risks can come from direct attacks aimed at the electric grid or other critical infrastructure which could impact the operations or security of the grid Arguably the greatest cyber threats to the grid have been attacks focused on manipulating industrial control systems which are increasingly connected to the internet to manage the production and regional flows of electricity 37 34 DOE GridEx IV Government and Industry Exercise Together to Improve the Response to Grid Security Emergencies November 21 2017 https www energy gov articles gridex-iv-government-and-industry-exercisetogether-improve-response-grid-security 35 NERC Grid Security Exercise GridEx IV—Lessons Learned public report March 2018 https www nerc com pa CI CIPOutreach GridEX GridEx%20IV%20Public%20Lessons%20Learned%20Report pdf 36 Ibid p 16 37 Idaho National Laboratory Cyber Threat and Vulnerability Analysis of the U S Electric Sector August 2016 https www energy gov sites prod files 2017 01 f34 Cyber%20Threat%20and%20Vulnerability%20Analysis%20of%2 0the%20U S %20Electric%20Sector pdf Congressional Research Service R45312 · VERSION 2 · UPDATED 8 Electric Grid Cybersecurity Industrial Control System Vulnerabilities ICS-CERT issues an annual report on ICS network vulnerabilities based on reports of cyber intrusions 38 Private companies also issue similar reports drawn from ICS-CERT alerts and their own sources As one example in 2017 the security firm Dragos which specializes in industrialcontrol systems looked at 163 new security vulnerabilities it found in industrial control devices It stated that the devices with the vulnerabilities it found were typically “insecure-by-design ” since they were located deep within ICS networks 39 It found that 61% of these vulnerabilities would likely cause a “severe operational impact” if exploited in a cyberattack Dragos said that about 15% of these vulnerabilities could be “leveraged to gain initial access into a control network ” meaning that a hacker would likely have to first have gained access to a network in order to exploit the vulnerability 40 Some Recent Malware Threats Cyber intrusions on the electric grid have resulted in the deposits of malware on grid ICS networks with the capability of causing damage or taking over certain aspects of system control or functionality Triton The Mandiant consulting company reported that it responded to a cyber intrusion at a critical infrastructure organization where malware was deployed to manipulate an industrial safety system 41 The targeted systems provided emergency shutdown capability for industrial processes We assess with moderate confidence that the attacker was developing the capability to cause physical damage and inadvertently shut down operations This malware which we call TRITON is an attack framework built to interact with Triconex Safety Instrumented System SIS controllers We have not attributed the incident to a threat actor though we believe the activity is consistent with a nation state preparing for an attack 42 Since the reported attack was focused on hacking SIS controllers FireEye a private security firm stated its opinion that the intrusion was intended to be a high-impact attack with physical consequences and that this was not the type of attack expected from a cyber-crime group aimed at financial extortion 43 The Triconex equipment referred to by FireEye is manufactured by Schneider Electric which reported that cyberattacks on its Triconex equipment were targeted 38 ICS-CERT Year in Review 2016 2017 https ics-cert us-cert gov Year-Review-2016 DRAGOS Industrial Control Vulnerabilities 2017 in Review 2018 https dragos com media 2017-ReviewIndustrial-Control-Vulnerabilities pdf 40 Ibid 41 FireEye Attackers Deploy New ICS Attack Framework “TRITON” and Cause Operational Disruption to Critical Infrastructure December 14 2017 https www fireeye com blog threat-research 2017 12 attackers-deploy-new-icsattack-framework-triton html 42 Ibid 43 “A SIS is an autonomous control system that independently monitors the status of the process under control If the process exceeds the parameters that define a hazardous state the SIS attempts to bring the process back into a safe state or automatically performs a safe shutdown of the process ” Ibid 39 Congressional Research Service R45312 · VERSION 2 · UPDATED 9 Electric Grid Cybersecurity The attack on the Schneider customer in part exploited a previously unknown or zero day vulnerability in Schneider’s Triconex Tricon safety system firmware And the hackers deployed a remote access trojan i e a malware program that includes a back door for administrative control over the target computer in the second stage of their exploitation a first for malware that targets industrial control systems 44 Crash Override Industroyer The malware deployed to attack a transmission system control center in the 2016 cyberattack in Ukraine was named “Industroyer” or “Crash Override” by cybersecurity companies ESET and Dragos 45 The malware accesses the same protocols used by electric grid systems to communicate with each other The platform fundamentally abuses the functionality of a targeted ICS system’s legitimate control system to achieve its intended effect While the known capabilities do not appear to be U S -focused it is important to recognize that the general tactics techniques and procedures used in CrashOverride could be leveraged with modified technical implementations to affect U S -based critical infrastructure With further modification CrashOverride or similar malware could have implications beyond electric power so all critical infrastructure organizations should be evaluating their systems to susceptibilities 46 This was reported to be the second known malware specifically designed to disrupt physical systems The first malware recognized as targeting SCADA systems was the STUXNET computer worm which was reported in 2010 to have destroyed centrifuges for uranium enrichment in Iran The virus subsequently proliferated with STUXNET subsequently being reported in 2012 to have spread to other company networks However no damage was reported to these other networks due to the malware being designed to attack specific equipment 47 BlackEnergy 2 and 3 In 2015 cyberattackers are reported to have used the BlackEnergy 2 malware to cause the grid failure in Ukraine 48 BlackEnergy 2 and 3 are versions of the BlackEnergy malware The malware uses a modular functionality on small office home office routers to collect intelligence exploit local area network devices and block actor-configurable network traffic The malware can render a device inoperable and has destructive functionality across routers network-attached storage devices and central processing unit CPU architectures running embedded Linux 49 Lily Hay Newman “Menacing Malware Shows the Dangers of Industrial System Sabotage ” WIRED January 18 2018 https www wired com story triton-malware-dangers-industrial-system-sabotage 45 Andy Greenberg “‘Crash Override’ The Malware That Took Down a Power Grid ” WIRED June 12 2017 https www wired com story crash-override-malware 46 U S Computer Emergency Readiness Team CrashOverride Malware Alert TA17-163A June 12 2017 https www us-cert gov ncas alerts TA17-163A 47 David Kushner The Real Story of Stuxnet IEEE February 26 p 2013 https spectrum ieee org telecom security the-real-story-of-stuxnet 48 “Recent open-source reports have circulated alleging that a December 23 2015 power outage in Ukraine was caused by BlackEnergy Malware ICS-CERT and US-CERT are working with the Ukrainian CERT and our international partners to analyze the malware and can confirm that a BlackEnergy 3 variant was present in the system ” ICS-CERT Ongoing Sophisticated Malware Campaign Compromising ICS Alert ICS-ALERT-14-281-01E November 10 2014 https ics-cert us-cert gov alerts ICS-ALERT-14-281-01B 49 US-CERT Cyber Actors Target Home and Office Routers and Networked Devices Worldwide Alert TA18-145A 44 Congressional Research Service R45312 · VERSION 2 · UPDATED 10 Electric Grid Cybersecurity BlackEnergy is a special potential vulnerability for critical infrastructure companies because the software is being used in an Advanced Persistent Threat APT form ostensibly to gather information 50 It can be used to monitor and interact with industrial control systems such as heating ventilation and air conditioning systems 51 Potential Cyber Threat to Grid from the Internet of Things Cyber threats to the grid can also emerge from attacks directed via Internet of Things IoT devices connected to networks 52 IoT devices have been increasingly targeted by botnet malware whereby the hacker takes over the operation of a large number of infected devices to launch denial-of-service or other cyberattacks 53 If such IoT cyberattacks were able to access electric utility operational or industrial control systems they could potentially impair these systems or cause electric power networks to operate based on manipulated conditions or false information 54 For example a potential IoT-based attack on residential or commercial thermostats could result in false power demand readings causing a utility to ramp up power production unnecessarily However some IoT threats can possibly be mitigated by deliberate IoT device design set-up and maintenance practices 55 Supply Chain Risks The electric utility industry increasingly depends on Operational Technology OT and Information Technology IT systems for the safe and efficient production and delivery of electricity OT and IT systems rely on hardware devices and software systems procured from a variety of manufacturers and vendors often from international sources The security of the May 25 2018 https www us-cert gov ncas alerts TA18-145A 50 “An advanced persistent threat APT is a network attack in which an unauthorized person gains access to a network and stays there undetected for a long period of time The intention of an APT attack is to steal data rather than to cause damage to the network or organization APT attacks target organizations in sectors with high-value information such as national defense manufacturing and the financial industry ” See https searchsecurity techtarget com definition advanced-persistent-threat-APT 51 Aravind Swaminathan and Stephen Hsieh Blackenergy Malware Highlights Special Confidentiality Considerations in Critical Infrastructure Breach Investigations DLA Piper November 17 2015 https www technologyslegaledge com 2014 11 blackenergy-malware-highlights-special-confidentialityconsiderations-in-critical-infrastructure-breach-investigations 52 IoT devices “include smart TVs smart speakers toys wearables and smart appliances Smart meters commercial security systems and smart city technologies—such as those used to monitor traffic and weather conditions—are examples of industrial and enterprise IoT devices Other technologies including smart air conditioning smart thermostats smart lighting and smart security span home enterprise and industrial uses ” TechTarget Iot Devices Internet of Things Devices 2018 https internetofthingsagenda techtarget com definition IoT-device 53 A denial-of-service attack is an attempt to make a machine or network resource unavailable to those attempting to reach it Quora What are Different Types of Cyberattacks 2018 https www quora com What-are-different-types-ofcyber-attacks 54 “The Mirai botnet took down Etsy GitHub Netflix Shopify SoundCloud Spotify Twitter and a number of other major websites ” Jack Wallen Five Nightmarish Attacks that Show the Risks of IoT Security June 1 2017 https www zdnet com article 5-nightmarish-attacks-that-show-the-risks-of-iot-security 55 “From looking at these attacks it should be clear that the onus for preventing takedown by IoT is on both the user and the device developer Going forward every IoT device should ship with an updated kernel firmware and include the ability to regularly update as new vulnerabilities are found At the same time anyone who deploys an IoT device needs to take the time to change the default user password combination if available and constantly be on the lookout for suspect network activity Finally developers should seriously consider making default password change a requirement upon initial deployment of the device ” Ibid Congressional Research Service R45312 · VERSION 2 · UPDATED 11 Electric Grid Cybersecurity design manufacture and patch management practices of these devices and systems is a potential vulnerability due to their global nature and the general lack of consistent oversight of standards and practices to prevent impaired or compromised functionality 56 Managing cyber supply chain risks require ensuring the integrity security quality and resilience of the supply chain and its products and services Cyber supply chain risks may include insertion of counterfeits unauthorized production tampering theft insertion of malicious software and hardware as well as poor manufacturing and development practices in the cyber supply chain 57 The components of smart grid devices present another potential vulnerability 58 Most of the smart meter sensor and other equipment makers are international companies who obtain their components from multinational sources Taiwan Singapore China and South Korea are among the largest overseas manufacturers of semiconductors and microprocessors for smart devices The reliable operation of semiconductor- and microprocessor-based devices is based on the low-level firmware controlling the devices’ basic functions 59 Firmware in the form of fixed machinelanguage code is found in almost all the electronic devices making up smarter grid products such as programmable controllers and programmable logic arrays If access were gained to such devices especially during the manufacturing process a section of code could be covertly inserted in the device and activated in such a way as to impair its functioning in a reliable manner Since testing all such devices is likely impractical some might suggest random or statistically based testing of the firmware in smarter grid devices But the impairment would not need to be placed in all such devices coming off an assembly line If a large enough sample were impaired the effect might be enough to cast doubt on the reliability of a whole class of such devices Older legacy systems may also be affected by potential supply chain vulnerabilities Legacy systems are a challenging vulnerability because upgrades and repairs of equipment may not include the installation of up-to-date security-focused patches In 2016 FERC issued Order No 829 directing NERC to develop a Critical Infrastructure Protection reliability standard that would require affected entities to develop and implement a plan that includes security controls for supply chain management for industrial control system hardware software and services associated with bulk electric system operations 60 According to FERC the new or modified reliability standard should address software integrity and authenticity vendor remote access information system planning and vendor risk management and procurement controls FERC states that there is no requirement for any specific controls nor does FERC require any “one-size-fits-all” requirement According to FERC the new or modified reliability standard 56 For further information see CRS In Focus IF10920 Cyber Supply Chain Risk Management An Introduction by Chris Jaikaran 57 National Institute of Standards and Technology Cyber Supply Chain Risk Management 2018 https csrc nist gov Projects Supply-Chain-Risk-Management 58 CRS Report R41886 The Smart Grid and Cybersecurity—Regulatory Policy and Issues by Richard J Campbell 59 Firmware is software that is embedded in a hardware device that allows reading and executing the software but does not allow modification e g writing or deleting data by an end user See http www its bldrdoc gov fs-1037 dir-015 _2236 htm 60 156 FERC ¶61 050 Congressional Research Service R45312 · VERSION 2 · UPDATED 12 Electric Grid Cybersecurity should instead require responsible entities to develop a plan to meet the four objectives while providing flexibility to responsible entities as to how to meet those objectives 61 In September 2017 NERC submitted a petition for approval of the new Reliability Standard CIP013-1 addressing supply chain risk management and proposed revisions to two existing reliability standards i e CIP-005-6 and CIP-010-3 62 The proposed set of new and revised standards would address cybersecurity risks in the supply chain by establishing and implementing organizationally defined processes that integrate a cybersecurity risk management framework proposed CIP-013-1 implementing methods to identify active vendor remote access sessions and disable active vendor remote access when necessary proposed modification to CIP-005-5 and verifying the identity of software publishers and the integrity of all software and patches intended for use on BES Cyber Systems proposed modification to CIP010-2 Other Grid Cybersecurity Issues There are gaps in cybersecurity for electric power and energy systems Some gaps are related to regulatory jurisdiction while other gaps may relate to cost and relative complexity to address the issue But considering the potential impact of a major grid cybersecurity event the gaps may require further attention Operation Technology OT Systems OT systems are often used by electric utilities to monitor and control power production processes While these technologies have been considered air-gapped i e separate from IT systems modernization of ICS networks has led to OT and IT systems becoming increasingly interconnected 63 And while a lot of attention has been focused on IT system cybersecurity this is not always the case for OT networks OT systems are often directly connected to the Internet in some cases so that third-party vendors can remotely connect to the system to perform diagnostics and maintenance In many of these instances the OT systems are not protected by a firewall and are outdated so they lack modern security features that would typically be used to protect an internetfacing connection e g multi-factor authentication strong passwords logging and monitoring 64 61 FERC Revised Critical Infrastructure Protection Reliability Standards Order No 829 July 21 2016 https ferc gov whats-new comm-meet 2016 072116 E-8 pdf 62 NERC Reliability Standards for the Bulk Electric Systems of North America July 3 2018 https www nerc com pa Stand Reliability%20Standards%20Complete%20Set RSCompleteSet pdf 63 “OT also often includes control room applications such as supervisory control and data acquisition SCADA systems that monitor the network reaching out to devices as complex as substation gateways or as simple as sensors ” Jeff Meyers How the Convergence of IT and OT Enables Smart Grid Development Schneider Electric 2013 http www2 schneider-electric com documents support white-papers electric-utilities How-the-Convergence-of-ITand-OT-Enables-Smart-Grid-Development pdf 64 Price Waterhouse Coopers Cyber Savvy Securing Operational Technology Assets December 2015 https www pwc com au pdf cyber-savvy-securing-operational-technology-assets pdf Congressional Research Service R45312 · VERSION 2 · UPDATED 13 Electric Grid Cybersecurity Economic challenges resource constraints business requirements and the pace of technological change are factors which are reported as making it nearly impractical to completely segregate OT networks from IT networks 65 Human Factor in Cybersecurity Many cybersecurity breaches are caused by individuals falling prey to phishing or similar attacks which are used to gain credentials to access utility systems 66 The human factor is thus considered by many to be the weakest link in cybersecurity This was the case in Ukraine as hackers sent out malware-carrying emails After links in the emails were opened by legitimate users hackers acquired the credentials needed to access control and operations systems to cause blackouts at regional distribution utilities 67 Development and deployment of better tools to secure the human interface could potentially reduce cybersecurity threats via email systems in particular In the meantime targeted phishing attacks are reported to be increasing In September 2017 Dragos picked up a new adversary code-named “Covellite ” Covellite has been targeting electric utilities in the U S Europe and parts of East Asia with spear-phishing attacks that employ code and infrastructure eerily similar to that used by the so-called Lazarus Group the most destructive and outright criminal of the statesponsored hacking gangs 68 Multifactor authentication is one security method focused on the human factor as it requires two or more credentials i e a password a biometric factor and or a security token to verify an individual’s identity prior to gaining access to a network 69 Therefore a combination of something you know i e a password something you have i e a token or something you are i e a biometric establishes you as a legitimate user Electric Power Cybersecurity Gaps FERC has authority over wholesale power sales and the transmission of electricity in interstate commerce while states have authority over retail sales by electric distribution systems FERC acknowledged that the Energy Policy Act of 2005 excluded local distribution systems from its reliability mandate under Section 215 of the Federal Power Act as not being part of the bulk power system FERC’s revised 2012 definition brought some of these larger distribution system components under BES regulation without bringing the distribution utilities under FERC’s 65 Ibid According to the US-CERT “Phishing is an attempt by an individual or group to solicit personal information from unsuspecting users by employing social engineering techniques Phishing emails are crafted to appear as if they have been sent from a legitimate organization or known individual These emails often attempt to entice users to click on a link that will take the user to a fraudulent website that appears legitimate The user then may be asked to provide personal information such as account usernames and passwords that can further expose them to future compromises Additionally these fraudulent websites may contain malicious code ” at https www us-cert gov report-phishing 67 Mathew J Schwartz More Phishing Attacks Target Ukraine Energy Sector Information Security Media Group January 22 2016 http www bankinfosecurity com phishing-attacks-again-target-ukraine-energy-sector-a-8822 op-1 68 Daily Beast North Korean Hackers May Be Developing Malware That Could Shut Down the U S Power Grid March 1 2018 https www thedailybeast com north-korean-hackers-may-be-developing-malware-that-could-shutdown-the-us-power-grid ref scroll 69 TechTarget Network Multifactor Authentication 2018 https searchsecurity techtarget com definition multifactorauthentication-MFA 66 Congressional Research Service R45312 · VERSION 2 · UPDATED 14 Electric Grid Cybersecurity broader jurisdiction However most distribution systems are not required to comply with NERC CIP cybersecurity standards Mutual Dependency of Critical Infrastructure Electricity production depends in large part upon other critical infrastructure sectors for fuel fuel delivery and support systems PPD-21 also establishes Energy and Communications systems as “uniquely critical” infrastructure 70 NERC itself concluded in its report on GridEx III that after a major grid disruption restarting generation and energizing transmission and distribution systems would be a first priority Restoring service to communications systems oil and gas water supply treatment and hospital customers would be a secondary priority However while the bulk electric system has mandatory and enforceable physical and cybersecurity rules other critical infrastructure needed for the electric power sector to function does not It is unlikely that an adversary capable of causing extreme impairment to the electric power system would overlook other less protected critical infrastructure Cybersecurity risks against the power and pipeline sectors are similar as both use similar control systems and there appears to be a broad consensus that cyber threats to this infrastructure are on the rise Furthermore with ever-greater physical interdependency between electricity generators and the natural gas pipelines that supply their fuel many in Congress recognize that grid and pipeline cybersecurity are intertwined 71 Artificial Intelligence for Cybersecurity With the introduction of digital smart grid technologies to enhance and modernize grid operations the speed and processing power of microprocessor-based ICS networks enhances the efficiency and control of power production and flows across electricity transmission and distribution systems While the benefits to the electric power system and its users are many there are potential risks as many IT and OT systems are connected to the internet to improve data collection and information sharing However this exposure to the internet leads to increased cybersecurity risks Artificial Intelligence Artificial Intelligence AI is one of the technologies being deployed to mitigate cybersecurity risks AI is a combination of computational technologies machines and software which have the capability to learn from inputs and be self-directed AI allows computer systems to simulate human learning and problem solving 72 Artificial intelligence algorithms are designed to make decisions often using real-time data They are unlike passive machines that are capable only of mechanical or predetermined responses Using sensors digital data or remote inputs they combine information from a variety of different sources analyze the material instantly and act on the insights derived from those data With massive improvements in storage systems 70 See Presidential Policy Directive-21 PPD-21 Critical Infrastructure Security and Resilience at https obamawhitehouse archives gov the-press-office 2013 02 12 presidential-policy-directive-critical-infrastructuresecurity-and-resil 71 CRS Report R44939 Cybersecurity for Energy Delivery Systems DOE Programs by Paul W Parfomak Chris Jaikaran and Richard J Campbell 72 For more information on AI see CRS In Focus IF10608 Overview of Artificial Intelligence by Laurie A Harris Congressional Research Service R45312 · VERSION 2 · UPDATED 15 Electric Grid Cybersecurity processing speeds and analytic techniques they are capable of tremendous sophistication in analysis and decision making 73 The speed of processing of AI systems is currently seen as providing protection for ICS and other networks that human operators may not be able to match especially as cyberattackers are employing increasingly sophisticated methodologies 74 One form of AI is machine learning—algorithms based on statistical techniques—which gives computer systems the ability to learn from a set of situations and make decisions based upon alternative scenarios in reaction to those situations rather than from programmer instructions The algorithms also adapt in response to new data and experiences to improve efficacy over time 75 Under these circumstances AI can potentially respond to a cyberattack scenario far more quickly than a human decisionmaker Data Analytics Electric utilities are collecting massive amounts of data from ICS networks and customerinformation systems Generally this accumulation is referred to as “big data ” Big data refers to the growth in the volume of structured and unstructured data the speed at which it is created and collected and the scope of how many data points are covered Big data often comes from multiple sources and arrives in multiple formats 76 Using data analytic techniques big data can be turned into useful information 77 Highperformance computing can take advantage of fast processing to examine data sets collected from smart grid systems into operational information providing insights into customer behavior It can also be used to recognize or potentially predict patterns or trends in data of new physical or cybersecurity threats to the grid Risks with AI and Machine Learning The processing speed of smart grid devices coupled with the use of AI systems also presents a potential cybersecurity vulnerability AI systems learn from experience and some observers say that these systems may be of limited use in cybersecurity defenses Machine learning decisions are made based on the data the machine learning are trained and tested on Machine learning is also subject to bias inherent in the data used to train the machines as the coding reflects the preconceptions of the coding’s programmers AI systems are typically only as good as the data on which they are trained They crystallize any biases or falsehoods found in their training data Barocas S and A D Selbst “Big Data’s Disparate Impact ” California Law Review vol 104 2016 The application of AI 73 Darrell M West and John R Allen How Artificial Intelligence Is Transforming the World Brookings Institution April 24 2018 https www brookings edu research how-artificial-intelligence-is-transforming-the-world 74 Salvador Llopis Sanchez Artificial Intelligence AI Enabled Cyber Defence European Defence Matters 2018 https www eda europa eu webzine issue14 cover-story artificial-intelligence- ai -enabled-cyber-defence 75 DOE An Executive’s Guide to AI https www energy gov sites prod files 2018 05 f51 An-executives-guide-toAI pdf 76 Definition of Big Data at https www investopedia com terms b big-data asp 77 “Data analytics is the process of examining data sets in order to draw conclusions about the information they contain increasingly with the aid of specialized systems and software Data analytics technologies and techniques are widely used in commercial industries to enable organizations to make more-informed business decisions and by scientists and researchers to verify or disprove scientific models theories and hypotheses ” See http searchdatamanagement techtarget com definition data-analytics Congressional Research Service R45312 · VERSION 2 · UPDATED 16 Electric Grid Cybersecurity to surveillance or cybersecurity for national security opens a new attack vector based on this data diet vulnerability Adversaries may learn how to systematically feed disinformation to AI surveillance systems essentially creating an unwitting automated double agent 78 Thus the bias of the programming can restrict how the machine learning addresses a situation However AI is a tool that can be used for offensive as well as defensive cybersecurity applications The next generation of situation-aware malware will use AI to behave like a human attacker performing reconnaissance identifying targets choosing methods of attack and intelligently evading detection Just as organizations can use artificial intelligence to enhance their security posture cybercriminals may begin to use it to build smarter malware 79 Adversaries may discover how to use AI to stage future attacks on the grid designed to disguise the intrusion and then overwhelm defenses One factor restricting intelligence in malware is the need for small malware payloads to prevent detection… But it is conceivable that future developments in swarm or distributed AI may result in strategic botnets with small malware payloads but devastating effects 80 Improving Grid Cybersecurity The Aurora simulation in 2007 was the first known event which proved that power plants could be vulnerable to a cyberattack An AURORA attack results when a circuit breaker or breakers are opened and closed resulting in an out-of-phase condition that can damage alternating current AC equipment connected to the grid A demonstration of this for the Department of Homeland Security conducted at the Idaho National Laboratory INL in 2007 was broadcast by CNN 81 AURORA demonstrated how a cyberattack could be used to destroy power generation equipment 82 Three years later the Stuxnet attack against the industrial control system of an Iranian nuclear fuel enrichment plant provided the next warning 83 Electric utilities were now aware that they must be prepared to address cyberthreats from a number of potential sources 78 Osonde A Osoba and William Welser IV The Risks of Artificial Intelligence to Security and the Future of Work RAND Corporation PE-237-RC 2017 2017 https www rand org content dam rand pubs perspectives PE200 PE237 RAND_PE237 pdf 79 Derek Manky Artificial Intelligence Cybersecurity Friend or Foe InformationWeek May 11 2017 https www darkreading com threat-intelligence artificial-intelligence-cybersecurity-friend-or-foe- a d-id 1328838 80 Osonde A Osoba and William Welser IV The Risks of Artificial Intelligence to Security and the Future of Work RAND Corporation PE-237-RC 2017 2017 https www rand org content dam rand pubs perspectives PE200 PE237 RAND_PE237 pdf 81 Michael Swearingen Steven Brunasso and Joe Weiss et al What You Need to Know and Don’t About the AURORA Vulnerability Power Magazine September 1 2013 http www powermag com what-you-need-to-knowand-dont-about-the-aurora-vulnerability printmode 1 82 Jeanne Meserve Sources Staged Cyberattack reveals Vulnerability in Power Grid CNN September 26 2007 http www cnn com 2007 US 09 26 power at risk index html 83 David Kushner The Real Story of Stuxnet IEEE Spectrum February 26 2013 http spectrum ieee org telecom security the-real-story-of-stuxnet Congressional Research Service R45312 · VERSION 2 · UPDATED 17 Electric Grid Cybersecurity Cybersecurity threats can arise from a number of sources including deliberate cyberattacks by professional hackers and acts of malice from discontented current or former employees 84 They can also result from professional attackers industrial spies and organized crime groups 85 and other groups with hacking capabilities such as hacktivists 86 However some observers would say that while terrorists87 e g in seeking to damage the U S economy may be able to buy the technical capacity for a cyberattack on the grid from hacktivists they would be more likely to seek an attack causing direct physical destruction Increasing Cyber Monitoring and Incident Reporting NERC aims to increase monitoring of the bulk electric system and has proposed a plan for the EISAC to be staffed 24 hours daily NERC states in its proposed 2019 budget that 24x7 onsite capabilities could provide significant benefits to members including 1 timely analysis and information sharing regarding developing physical or cyber security incidents that are discovered or occur outside of normal hours and 2 the continued development of actionable intelligence during the overnight and weekend hours to enhance industry’s preparation for and response to any potential physical or cyber security threat or incident 88 “National cyber warfare programs are unique in posing a threat along the entire spectrum of objectives that might harm US interests These threats range from propaganda and low-level nuisance web page defacements to espionage and serious disruption with loss of life and extensive infrastructure disruption Among the array of cyber threats as seen today only government-sponsored programs are developing capabilities with the future prospect of causing widespread long-duration damage to U S critical infrastructures The tradecraft needed to effectively employ technology and tools remains an important limiting factor particularly against more difficult targets such as classified networks or critical infrastructures For the next 5 to 10 years only nation states appear to have the discipline commitment and resources to fully develop capabilities to attack critical infrastructures Their goal is to weaken disrupt or destroy the U S Their sub-goals include espionage for attack purposes espionage for technology advancement disruption of infrastructure to attack the US economy full scale attack of the infrastructure when attacked by the U S to damage the ability of the US to continue its attacks ” Industrial Control Systems Cyber Emergency Response Team Cyber Threat Source Descriptions 2016 https ics-cert us-cert gov content cyber-threatsource-descriptions#hack Hereinafter ICST 85 “International corporate spies and organized crime organizations pose a medium-level threat to the US through their ability to conduct industrial espionage and large-scale monetary theft as well as their ability to hire or develop hacker talent Their goals are profit based Their sub-goals include attacks on infrastructure for profit to competitors or other groups listed above theft of trade secrets and gain access and blackmail affected industry using potential public exposure as a threat ” ICST 86 “Hacktivists form a small foreign population of politically active hackers that includes individuals and groups with anti-U S motives They pose a medium-level threat of carrying out an isolated but damaging attack Most international hacktivist groups appear bent on propaganda rather than damage to critical infrastructures Their goal is to support their political agenda Their sub-goals are propaganda and causing damage to achieve notoriety for their cause ” ICST 87 “Traditional terrorist adversaries of the U S despite their intentions to damage U S interests are less developed in their computer network capabilities and propensity to pursue cyber means than are other types of adversaries They are likely therefore to pose only a limited cyber threat Since bombs still work better than bytes terrorists are likely to stay focused on traditional attack methods in the near term We anticipate more substantial cyber threats are possible in the future as a more technically competent generation enters the ranks Their goal is to spread terror throughout the U S civilian population Their sub-goals include attacks to cause 50 000 or more casualties within the U S and attacks to weaken the U S economy to detract from the Global War on Terror ” ICST 88 NERC 2019 Business Plan and Budget Draft 1 May 18 2018 https www nerc com gov bot FINANCE 19BusPlanBud 2019%20NERC%20Business%20Plan%20and%20Budget pdf 84 Congressional Research Service R45312 · VERSION 2 · UPDATED 18 Electric Grid Cybersecurity FERC Increasing Reporting of Cyber Incidents FERC also seeks increased reporting of cyber incidents Currently under critical infrastructure protection reliability standard CIP-008-5 for Cyber Security—Incident Reporting and Response Planning incidents must be reported only if they have compromised or disrupted one or more reliability tasks FERC has directed NERC to expand the CIP-008 standard to require reporting of any attempts to break into a company’s networks rather than only reporting incidents that compromise a company’s critical operations Responsible entities must report cyber security incidents that compromise or attempt to compromise a responsible entity’s Electronic Security Perimeter ESP or associated Electronic Access Control or Monitoring Systems EACMS Cyber security incident reports should be standardized to improve the quality of reporting and allow for ease of comparison across reports analysis and trending Cyber security incident reports would be sent to those organizations best equipped to assess threats and communicate them to industry Specifically reports will continue to be sent to the Electricity Information Sharing and Analysis Center E-ISAC the reports would also be sent to the Department of Homeland Security’s Industrial Control Systems Cyber Emergency Response Team ICS-CERT NERC would file an annual public and anonymized summary of the reports with the Commission 89 Mandatory DOE Reporting of Grid Incidents and Disturbances DOE for its part has established its own mandatory reporting requirements for U S electric utilities experiencing emergency incidents and disturbances 90 Form OE-417 alerts the Department of Energy to electrical emergency incidents and disruptions The ability of the DOE to quickly respond to energy emergencies that may impact the nation’s infrastructure and help alleviate or prevent further disruptions depends on the industry’s prompt response As such the timely filing of this form is of paramount importance 91 Electric power incidents and outages have various criteria for reporting depending on the level of urgency of the situation An Emergency Alert must be filed within one hour of an incident and includes physical attacks causing major interruptions or impacts to critical infrastructure facilities or to operations cyber incidents causing interruptions of electrical system operations and incidences of uncontrolled loss of 300 Megawatts or more of firm system loads i e power provided to customers that is continuously available on demand and which is subject to interruption only under extreme circumstances for 15 minutes or more from a single incident 92 Normal reports due within six hours of company incidents and System reports for wider system issues due by the later of 24 hours after the recognition of the incident or by the end of the next business day have lesser criteria for notification of DOE 93 89 FERC FERC Requires Expanded Cyber Security Incident Reporting July 19 2018 https www ferc gov media news-releases 2018 2018-3 07-19-18-E-1 asp# W1X8jFNG2go 90 DOE Electric Emergency Incident and Disturbance Report Form OE-417 2018 https www oe netl doe gov docs OE417_Form_Instructions_05312021 pdf 91 Ibid 92 Ibid Any incidence of one or more of the criteria occurring can necessitate an Emergency Alert report 93 Ibid pp 2-3 Congressional Research Service R45312 · VERSION 2 · UPDATED 19 Electric Grid Cybersecurity DOE states that in addition to national security response the information collected by Form OE417 is to be used for reporting on electric power emergency incidents and disturbances in monthly Energy Information Administration EIA reports and that it may use the data to develop legislative recommendations and reports to Congress and as a basis for DOE investigations following severe prolonged or repeated electric power reliability problems Enhancing the Threat Risk Assessment Many cybersecurity actions are reactive to the last threat discovered While intrusion detection is considered a priority some experts say that mitigation of cyber threats requires a focus on attackers not the attacks to address their motivations e g to extort money or to cause damage Others might differ saying that the focus should be on the attack and the system vulnerability exploited Some utilities are undertaking security improvements in modernization programs while other improvements would potentially have to be undertaken as special projects because of limitations for cost recovery under traditional cost-of-service ratemaking regulations under state government jurisdiction 94 In such instances the improvements may have to be justified as “used or useful” in providing electricity service to customers in utility rate cases Very often the relative level of sophistication of the threat is related to the origin of the threat Since many cyberthreats appear to originate from foreign entities including some with nation state affinities intelligence on the existence and nature of the threat as well as the capability of dealing with the threat often relies on the federal government’s national security apparatus Therefore the information communicated from the government is generally more useful when it is both timely and relevant as to the severity of a threat and communicates whether a need exists for immediate action The electricity industry then provides the expertise necessary for understanding the relative risk to the grid of the potential threat and the appropriate avenues for communicating the threat information The National Cybersecurity and Communications Integration Center NCCIC under the Department of Homeland Security’s National Protection and Programs Directorate largely has the role of informing the electricity industry of cyber and physical threats to the grid 95 The NCCIC is focused on cyber situational awareness incident response and management and coordinates with the Electricity Information Sharing and Analysis Center E-ISAC operated by the North American Electric Reliability Corporation The E-ISAC gathers and analyzes security information coordinates incident management and communicates mitigation strategies with stakeholders within the Electricity Subsector across interdependent sectors and with government partners 96 The E-ISAC runs the voluntary NERC Cybersecurity Risk Information Sharing Program which aims to facilitate a nearly real-time sharing of government enhanced threat information enhance 94 Many utilities operate under traditional regulatory regimes where the cost of providing electric power to end-use customers is subject to approval by state authorized public utility commissions or similar state organizations 95 “The NCCIC works closely with those federal departments and agencies most responsible for securing the government’s cyber and communications systems and actively engages with private sector companies and institutions state local tribal and territorial governments and international counterparts Each group of stakeholders represents a community of practice working together to protect the portions of critical information technology that they own operate manage or interact with ” DHS “About the National Cybersecurity and Communications Integration Center ” November 4 2014 http www dhs gov about-national-cybersecurity-communications-integration-center 96 E-ISAC Electricity Information Sharing and Analysis Center 2016 https www esisac com Congressional Research Service R45312 · VERSION 2 · UPDATED 20 Electric Grid Cybersecurity situational awareness and better protect critical infrastructure 97 CRISP deploys passive sensors called Information-Sharing Devices ISDs on participant company networks The ISDs send encrypted data to an analysis center operated by the Pacific Northwest National Laboratory 98 which analyzes the data sending alerts with mitigation measures to CRISP participants through a secure network 99 As of the end of 2015 75% of U S electricity customers were covered by companies which had deployed CRISP 100 The Electricity Subsector Coordinating Council ESCC an entity led by industry chief executive officers that is the principal liaison between the federal government and the electric power sector has called for the E-ISAC to be the “central source of information sharing between the Electricity Subsector and the government ”101 Building Resiliency into the Grid There has been speculation that a major cyberattack may be inevitable given the many diverse actors in the cyber threat space with both political and apolitical motivations Given such scenarios some resources are focused on actions and technologies which can aid recovery from a cyberattack Several potential courses to improve resiliency and which may quicken recovery efforts from a potential attack on the grid are discussed below Building the Smart Grid New technologies are being considered for their potential to enhance electric power transmission and distribution system resiliency For example a 2013 report from the Electric Power Research Institute EPRI reviews innovative technologies for their ability to make the distribution system more resilient to weather-related power outages or terrorist attacks 102 These innovations range from use of plug-in electric vehicles and solar photovoltaic systems as back-up power supplies for residences to community energy storage projects using batteries Smart grid technologies have also been proposed for reliability and resiliency Sensors and automated controls can use real-time data to reconfigure a utility network to isolate problems 103 One such system is called Dynamic Circuit Reconfiguration 104 97 Marcus Sachs NERC Comments on Reliability FERC FERC Reliability Technical Conference June 1 2016 http www ferc gov CalendarFiles 20160601082816-Sachs %20NERC pdf Hereinafter FERCN 98 The Pacific Northwest National Laboratory has a national security function through its connection with DOE See Pacific Northwest National Laboratory National Security July 2016 http www pnnl gov nationalsecurity 99 American Public Power Association NERC Plans Major New Initiative on Cybersecurity Information Sharing September 4 2014 http publicpower com 2014 nerc-plans-major-new-initiative-cybersecurity-information-sharing 100 Testimony of William Spence Chief Executive Officer PPL Corporation U S Congress House Committee on Transportation and Infrastructure Subcommittee on Economic Development Public Buildings and Emergency Management Blackout Are We Prepared to Manage the Aftermath of a Cyber-Attack or Other Failure of the Electrical Grid 114th Cong 1st sess April 14 2016 101 FERCN p 3 102 Electric Power Research Institute Enhancing Distribution Resiliency Opportunities for Applying Innovative Technologies January 11 2013 http www epri com abstracts Pages ProductAbstract aspx ProductId 000000000001026889 Hereinafter EPRI 103 See CRS Report R45156 The Smart Grid Status and Outlook by Richard J Campbell 104 “Many utilities have successfully deployed Distribution Automation with Optimal Network Reconfiguration These systems involve the deployment of automated distribution switches sectionalizers reclosers sensors communications control systems and data analytics to automatically reconfigure circuit connections in order to maximize service restoration ” EPRI p 7 Congressional Research Service R45312 · VERSION 2 · UPDATED 21 Electric Grid Cybersecurity Once deployed these systems serve two roles First they limit the number of customers affected by faults Second once the fault is isolated the systems enable restoration of service to unaffected sections from adjacent circuit connections 105 EPRI emphasizes that such practices “must be tailored to events of different magnitudes and to different types of disruption wind flood tsunami earthquake and terrorist or cyber attacks etc ”106 While smart grid solutions would utilize fast-acting sensors and tools to gather and analyze information the controls for the system would likely have to be located in a combination of central and distributed locations to aid a resilient cybersecurity strategy However distributed data centers powered by energy supplies independent of the grid may be needed to ensure that recovery from a cyberattack is not hampered by the loss of information and data needed to recover operations and business systems Distributed Energy Resources Distributed resources107 and microgrids108 are also being considered both in terms of making the current grid more resilient and as an increased element of the future grid The state of New York among others has been working with investor-owned electric utilities on a plan to deploy distributed resources at scale as part of its plan to modernize its energy systems 109 The ability of microgrids to operate independently of the grid has potential in a cyberattack or other emergency 110 and power can be generated by fossil fuel combined heat and power plants or renewable energy systems Microgrids are also being investigated by the DOE as an element of a modern energy future for the grid 111 Distributed generation112 is growing and could potentially be a source for black start113 power in the event of a grid failure but these smaller power plants 105 Ibid EPRI p 8 107 Distributed resources include energy efficiency demand response solar PV wind power energy storage combined heat and power cogeneration and other technologies 108 A microgrid may be defined as “any collection of interconnected loads and distributed energy resources i e distributed generation within clearly defined electrical boundaries that can be controlled as a single entity and that can operate in both grid-connected or island mode i e non-grid connected ” Gail Reitenbach “Interest Growing in Commercial and Community Microgrids ” Power Magazine June 26 2014 http www powermag com interestgrowing-in-commercial-and-community-microgrids 109 New York State Department of Public Service Reforming the Energy Vision January 28 2016 http www3 dps ny gov W PSCWeb nsf All CC4F2EFA3A23551585257DEA007DCFE2 110 However microgrids must have adequately protected operational control systems which will enable quick disconnection and independent operation from the grid if a fault or grid failure is detected 111 DOE Energy Department Announces Funding to Improve the Resiliency of the Electric Grid 2014 http energy gov articles energy-department-announces-funding-improve-resiliency-electric-grid 112 Distributed Generation DG is the term used to describe electric power generated at or near the point of consumption i e the customer or load DG thus differs from base load power plants mostly coal and nuclear power units which were designed for economies of scale and located usually at some distance from where the electricity is consumed DG includes traditional backup power sources such as the large gas- or diesel-powered generators used by institutions and companies combined heat and power facilities used for industrial district and community power generation and renewable electricity power systems used by some businesses and residences 113 “A black start unit is one that can start its own power without support from the grid in the event of a major system collapse or a system-wide blackout In the U S every region within the North American Electric Reliability Corp NERC has its own black start plan and procedures Each region also designates certain plants as black start units ” Lindsay Morris “Black Start Preparedness for Any Situation ” POWER Engineering July 1 2011 https www power-eng com articles print volume-115 issue-7 features black-start-preparedness-for-any-situation html 106 Congressional Research Service R45312 · VERSION 2 · UPDATED 22 Electric Grid Cybersecurity would have to be protected against cybersecurity attacks if they were to help in a black start situation Building a Strategic Reserve of Critical Components Large high voltage electric power transformers LPTs have received special attention as a critical component of the bulk electric system which could be targeted in physical and cyberattacks Reserves of LPTs are few since these are high-cost items and LPTs are not commonly manufactured in the United States LPTs require a fairly long lead time to manufacture and may be designed to meet a customer’s specifications The investor-owned electric utilities have had a transformer sharing program in place since 2006 with those utilities that wanted to participate 114 Nonetheless Section 61004 of the FAST Act required DOE to submit a plan to Congress evaluating the feasibility of establishing a Strategic Transformer Reserve for the storage in strategically located facilities of spare large power transformers and emergency mobile substations to temporarily replace critically damaged LPTs and substations In March 2017 DOE submitted a report to Congress on the strategic reserve highlighting the issues of time to build cost and potential federal ownership of a strategic reserve as well as issues of where to place and maintain a strategic reserve DOE found that given FERC’s approval of CIP-014 reliability standards supporting enhanced industry programs for spare transformer sharing might be a better way to achieve a strategic reserve DOE also stated that it is encouraging manufacturers to design transformers to meet high resilience standards for electromagnetic pulse EMP and geomagnetic disturbances GMD as well as physical and cybersecurity 115 However given industry’s general reticence to allocate funding for potentially high-impact but low-frequency events such as EMP attack GMD severe weather or seismic events as mentioned in the FAST Act it is unclear whether an enhanced industry approach alone would meet the concerns of many in Congress with regard to a strategic reserve Other Issues for Congress The electric power industry does not have the intelligence-gathering capabilities to deal with the many cyber and physical threats to the grid many of which appear to originate internationally Instead the U S government analyzes all-source intelligence to understand threats to the energy grid and shares that information with the electricity industry which has the capability and expertise to understand the risks posed to the grid How that information could be better disseminated and on a timelier basis has been raised as an issue by the electric power industry The bulk electric system is subject to mandatory and enforceable critical infrastructure protection rules for cyber and physical security under the FERC’s reliability mandate However the energy sector is one of 16 critical infrastructure sectors identified by the Department of Homeland Security Given that the grid relies on several of the other sectors for example for water and fuel 114 The Edison Electric Institute’s Spare Transformer Equipment Program STEP program is a pool of LPTs in various voltage classes and sizes Megavolt-amperes or MVA located at member utilities throughout North America Edison Electric Institute Spare Transformers 2018 http www eei org issuesandpolicy transmission Pages sparetransformers aspx 115 For example new performance measures may be established to improve resilience DOE Strategic Transformer Reserve March 2017 https www energy gov sites prod files 2017 04 f34 Strategic%20Transformer%20Reserve%20Report%20%20FINAL pdf Congressional Research Service R45312 · VERSION 2 · UPDATED 23 Electric Grid Cybersecurity transportation the question of whether these other sectors should also have similar mandatory standards focused on support of the electric power sector may be an issue for Congress to consider The electric power system in the United States is evolving but not consistently across sectors and regions of the country While some may say such inconsistencies may add a level of complexity that may make a nationwide cyber event more unlikely the consistent development of a modern electric power system would likely add to the prospects of U S economic health and competitiveness Policy options designed to ensure that the developing electric power system is as secure as possible will likely be a major consideration for Congress Recent Legislation 115th Congress The Grid Cybersecurity Research and Development Act H R 4120 introduced in October 2017 would require the DOE to develop an initiative to mitigate the consequences on the electric grid of cyberattacks by increasing grid cybersecurity DOE would also be required to work with other agencies and the private sector to develop guidance for cybersecurity research and development to improve electric sector cybersecurity NIST would be required to develop voluntary training standards and maintain a public database of cybersecurity training programs The ESCC would be required to develop a coordinated interagency strategic plan to advance grid cybersecurity capabilities The Pipeline and Liquefied Natural Gas Facility Cybersecurity Preparedness Act H R 5175 introduced in March 2018 would require the Secretary of Energy to carry out a program in consultation with other federal agencies states and the energy sector to ensure security resiliency and survivability of natural gas pipelines hazardous liquid pipelines and liquefied natural gas facilities The DOE would also be required to coordinate response and recovery to physical and cyber incidents impacting the energy sector and demonstrate advanced cybersecurity and technologies projects for physical and cybersecurity The Cyber Sense Act of 2018 H R 5239 introduced in March 2018 would establish a voluntary DOE program for testing product cybersecurity and technologies intended for use in the bulk-power system including products related to ICS It would also authorize the DOE to provide technical assistance to electric utilities product manufacturers and other electricity sector stakeholders to help mitigate cybersecurity vulnerabilities The Enhancing Grid Security through Public-Private Partnerships Act H R 5240 introduced in March 2018 would promote and advance physical and cybersecurity of electric utilities The bill would require the Secretary of Energy to carry out a program in concert with the Energy Reliability Organization industry stakeholders and other federal agencies to among other activities develop voluntary implementation of maturity models self-assessments and auditing methods to assess the physical and cybersecurity of electric utilities provide training for electric utilities to address and mitigate supply chain risks increase opportunities for sharing best practices assist with cybersecurity training for electric utilities and advance the cybersecurity of third-party vendors that work in partnerships with electric utilities The Promoting Cybersecurity for Rural Electric Utilities Act S 2991 introduced in June 2018 would amend the Rural Electrification Act of 1936 7 U S C 931 et seq to provide that cybersecurity and grid security improvements are eligible for electric loans and guarantees under that act Congressional Research Service R45312 · VERSION 2 · UPDATED 24 Electric Grid Cybersecurity Appendix Bulk Electric System Critical Infrastructure Protection Standards Table A-1 NERC Critical Infrastructure Protection Standards Bulk Electric System Standard Typea Name Description Current Standards CIP-002-5 1a C BES Cyber System Categorization To identify and categorize Bulk Electric System BES Cyber Systems and their associated BES Cyber Assets for the application of cyber security requirements commensurate with the adverse impact that loss compromise or misuse of those BES Cyber Systems could have on the reliable operation of the BES b Identification and categorization of BES Cyber Systems support appropriate protection against compromises that could lead to misoperation or instability in the BES CIP-003-6 C Security Management Controls To specify consistent and sustainable security management controls that establish responsibility and accountability to protect BES Cyber Systems against compromise that could lead to misoperation or instability in the BES CIP-004-6 C Personnel and Training To minimize the risk against compromise that could lead to misoperation or instability in the BES from individuals accessing BES Cyber Systems by requiring an appropriate level of personnel risk assessment training and security awareness in support of protecting BES Cyber Systems CIP-005-5 C Electronic Security Perimeter s To manage electronic access to BES Cyber Systems by specifying a controlled Electronic Security Perimeter in support of protecting BES Cyber Systems against compromise that could lead to misoperation or instability in the BES CIP-006-6 C Physical Security of BES Cyber Systems To manage physical access to BES Cyber Systems by specifying a physical security plan in support of protecting BES Cyber Systems against compromise that could lead to misoperation or instability in the BES CIP-007-6 C System Security Management To manage system security by specifying select technical operational and procedural requirements in support of protecting BES Cyber Systems against compromise that could lead to misoperation or instability in the BES CIP-008-5 C Incident Reporting and Response Planning To mitigate the risk to the reliable operation of the BES as the result of a Cyber Security Incident by specifying incident response requirements CIP-009-6 C Recovery Plans for BES Cyber Systems To recover reliability functions performed by BES Cyber Systems by specifying recovery plan requirements in support of the continued stability operability and reliability of the BES CIP-010-2 C Configuration Change Management and Vulnerability Assessments To prevent and detect unauthorized changes to BES Cyber Systems by specifying configuration change management and vulnerability assessment requirements in support of protecting BES Cyber Systems from compromise that could lead to misoperation or instability in the BES Congressional Research Service R45312 · VERSION 2 · UPDATED 25 Electric Grid Cybersecurity Standard Typea Name Description CIP-011-2 C Information Protection To prevent unauthorized access to BES Cyber System Information by specifying information protection requirements in support of protecting BES Cyber Systems against compromise that could lead to misoperation or instability in the BES CIP-014-2 P Physical Security To identify and protect Transmission stations and Transmission substations and their associated primary control centers that if rendered inoperable or damaged as a result of a physical attack could result in instability uncontrolled separation or Cascading within an Interconnection Filed and Pending FERC Approval CIP-005-6 C Electronic Security Perimeter s Modified to address certain directives in FERC Order No 829 CIP-010-3 C Configuration Change Management and Vulnerability Assessments Modified to address certain directives in FERC Order No 829 CIP-013-1 C Supply Chain Risk Management New standard per FERC Order No 829 cTo mitigate cyber security risks to the reliable operation of the Bulk Electric System by implementing security controls for supply chain risk management of BES Cyber Systems Source CRS See North American Electric Reliability Corporation CIP Standards at https www nerc com pa Stand Pages CIPStandards aspx Notes a Type indicates C—Cybersecurity or P—Physical Security Standard b One of the fundamental differences between Versions 4 and 5 of the CIP Cyber Security Standards is the shift from identifying Critical Cyber Assets to identifying BES Cyber Systems This change results from the review of the NIST Risk Management Framework and the use of an analogous term “information system” as the target for categorizing and applying security controls BES Cyber System is defined as “ o ne or more BES Cyber Assets logically grouped by a responsible entity to perform one or more reliability tasks for a functional entity ” Glossary of Terms Used in NERC Reliability Standards NERC Glossary http www nerc com files glossary_of_terms pdf The acronym BES refers to the bulk electric system c Revised Critical Infrastructure Protection Reliability Standards Order No 829 156 FERC ¶ 61 050 at P 43 2016 Author Information Richard J Campbell Specialist in Energy Policy Congressional Research Service R45312 · VERSION 2 · UPDATED 26 Electric Grid Cybersecurity Disclaimer This document was prepared by the Congressional Research Service CRS CRS serves as nonpartisan shared staff to congressional committees and Members of Congress It operates solely at the behest of and under the direction of Congress Information in a CRS Report should not be relied upon for purposes other than public understanding of information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role CRS Reports as a work of the United States Government are not subject to copyright protection in the United States Any CRS Report may be reproduced and distributed in its entirety without permission from CRS However as a CRS Report may include copyrighted images or material from a third party you may need to obtain the permission of the copyright holder if you wish to copy or otherwise use copyrighted material Congressional Research Service R45312 · VERSION 2 · UPDATED 27
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