Implementation Plan for Version 5 CIP Cyber Security Standards



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Implementation Plan for Version 5 CIP Cyber Security Standards April 10September 11, 2012 Prerequisite Approvals All Version 5 CIP Cyber Security Standards and the proposed additions, modifications, and retirements of terms to the Glossary of Terms used in NERC Reliability Standards must be approved before these standards can become effective. Applicable Standards The following standards and definitions, collectively referred to as Version 5 CIP Cyber Security Standards, 1 are covered by this Implementation Plan: CIP 002 5 Cyber Security BES Cyber System Categorization CIP 003 5 Cyber Security Security Management Controls CIP 004 5 Cyber Security Personnel and Training CIP 005 5 Cyber Security Electronic Security Perimeter(s) CIP 006 5 Cyber Security Physical Security of BES Cyber Systems CIP 007 5 Cyber Security Systems Security Management CIP 008 5 Cyber Security Incident Reporting and Response Planning CIP 009 5 Cyber Security Recovery Plans for BES Cyber Systems CIP 010 1 Cyber Security Configuration Change Management and Vulnerability Assessments CIP 011 1 Cyber Security Information Protection Definitions of Terms used in Version 5 CIP Cyber Security Standards document, which includes proposed additions, modifications, and retirements of terms to the Glossary of Terms used in NERC Reliability Standards. These standards and Definitions of Terms used in Version 5 CIP Cyber Security Standards are posted for ballot by NERC concurrently with this Implementation Plan. When these standards and Definitions of Terms used in Version 5 CIP Cyber Security Standards become effective, all prior versions of these standards are retired. 1 Although CIP-010-1 and CIP-011-1 are proposed as first versions, any reference to Version 5 CIP Cyber Security Standards includes CIP- 010-1 and CIP-011-1, in addition to CIP-002-5 through CIP-009-5, because CIP-010-1 and CIP-011-1 were developed as part of the Version 5 CIP Cyber Security Standards development process.

Compliance with Standards Once these standards and Definitions of Terms used in Version 5 CIP Cyber Security Standards become effective, the responsible entities identified in the Applicability Section of the standard must comply with the requirements. Proposed Effective Date for Version 5 CIP Cyber Security Standards Responsible entities shall comply with all requirements in CIP-002-5, CIP-003-5, CIP-004-5, CIP-005-5, CIP-006-5, CIP-007-5, CIP-008-5, CIP-009-5, CIP-010-1, and CIP-011-1 as follows: 1. 24 Months Minimum The Version 5 CIP Cyber Security Standards, except for CIP-003-5 R2, shall become effective on the later of July 1, 2015, or the first calendar day of the ninth calendar quarter after the effective date of the order providing applicable regulatory approval. CIP-003-5, Requirement R2, shall become effective on the later of July 1, 2016, or the first calendar day of the 13th calendar quarter after the effective date of the order providing applicable regulatory approval. Notwithstanding any order to the contrary, CIP-002-4 through CIP-009-4 do not become effective, and CIP-002-3 through CIP-009-3 remain in effect and are not retired until the effective date of the Version 5 CIP Cyber Security Standards under this implementation plan. 2 2. In those jurisdictions where no regulatory approval is required, the Version 5 CIP Cyber Security Standards, except for CIP-003-5 R2, shall become effective on the first day of the ninth calendar quarter following Board of Trustees approval, and CIP-003-5 R2 shall become effective on the first day of the 13th calendar quarter following Board of Trustees approval, or as otherwise made effective pursuant to the laws applicable to such ERO governmental authorities. Initial Performance of Certain Periodic Requirements Specific Version 5 CIP Cyber Security Standards have periodic requirements that contain time parameters for subsequent and recurring iterations of the requirement;, such as, but not limited to,... at least once eachevery 15 calendar year... months..., and responsible entities shall comply initially with those periodic requirements, as follows: 1. On or before the Effective Date of the Version 5 CIP Cyber Security Standards for the following requirements: CIP-002-5, Requirement R2 CIP-003-5 R4, Requirement R1 2. On or before the Effective Date of CIP-003-5, Requirement R2 for the following requirement: CIP-003-5, Requirement R2 2 In jurisdictions where CIP-002-4 through CIP-009-4 have not yet become effective according to their implementation plan (even if approved by order), this implementation plan and the Version 5 CIP Cyber Security Standards supersede and replace the implementation plan and standards for CIP-002-4 through CIP-009-4. 2

2.3. Within 14 calendar days after the Effective Date of the Version 5 CIP Cyber SecuritySecuirty Standards for the following requirements: CIP-007-5, Requirement R4, Part 4.5 3.4. Within 35 calendar days after the Effective Date of the Version 5 CIP Cyber SecuritySecuirty Standards for the following requirements: CIP-007-5, Requirement R3, Part 3.3 CIP-010-1, Requirement R2, Part 2.1 4.5. Within three calendar months after the Effective Date of the Version 5 CIP Cyber Security Standards for the following requirements: CIP-004-5 R6, Requirement R4, Part 6.54.2 5.6. Within 12 calendar months after the Effective Date of the Version 5 CIP Cyber Security Standards for the following requirements: CIP-004-5 R3, Requirement R2, Part 2.3.2 CIP-004-5 R6, Requirement R4, Parts 6.64.3 and 6.74.4 CIP-006-5, Requirement R3, Part 3.1 CIP-008-5, Requirement R2, Part 2.1 CIP-008-5, Requirement R3, Part 3.1 CIP-009-5, Requirement R2, Parts 2.1,2.2 and 2.23 CIP-009-5, Requirement R3, Part 3.1 CIP-010-5, Requirement R3, Parts 3.1 and 3.2 CIP-011-5, Requirement R1, Part 1.3 7. Within 24 calendar months after the Effective Date of the Version 5 CIP Cyber Security Standards for the following requirements: CIP-009-5, Requirement R2, Part 2.3 CIP-010-1, Requirement R3, Part 3.2 6.8. Within 7 years after the last personnel risk assessment that was performed pursuant to a previous version of the CIP Cyber Security Standards for a personnel risk assessment for the following requirement: CIP-004-5 R5, Requirement R3, Part 3.5.2. Previous Identity Verification A documented identity verification performed pursuant to a previous version of the CIP Cyber Security Standards does not need to be reperformed under CIP-004-5 R4, Part 4.1. 3

Planned or Unplanned Changes Resulting in a Higher Categorization Planned changes refer to any changes of the electric system or BES Cyber System, as described inidentied through the annual assessment under CIP-002-5, R1.1Requirement R2, which were planned and implemented by the responsible entity. For example, if an automation modernization activity is performed at a transmission substation, whereby Cyber Assets are installed that meet the criteria in CIP-002-5, Attachment 1, then the new BES Cyber System has been implemented as a result of a planned change, and must, therefore, be in compliance with the Version 5 CIP Cyber Security Standards upon the commissioning of the modernized transmission substation. In contrast, unplanned changes refer to any changes of the electric system or BES Cyber System, as described inidentied through the annual assessment under CIP-002-5, R1.1Requirement R2, which were not planned by the responsible entity. Consider the scenario where a particular BES Cyber System at a transmission substation does not meet the criteria in CIP-002-5, Attachment 1, then, later, an action is performed outside of that particular transmission substation; such as, a transmission line is constructed or retired, a generation plant is modified, changing its rated output, and that unchanged BES Cyber System may become a medium impact BES Cyber System based on the CIP-002-5, Attachment 1, criteria. For planned changes resulting in a higher categorization, the responsible entity shall comply with all applicable requirements in the Version 5 CIP Cyber Security Standards on the update of the identification and categorization of the affected BES Cyber System, as required in CIP-002-5, R1.1 and any applicable and associated Physical Control Systems, Electronic Control and Monitoring Systems and Protected Cyber Assets, with additional time to comply for requirements in the same manner as those timelines specified in the section Initial Performance of Certain Periodic Requirements above. For unplanned changes resulting in a higher categorization, the responsible entity shall comply with all applicable requirements in the Version 5 CIP Cyber Security Standards, according to the following timelines, following the identification and categorization of the affected BES Cyber System, as required in CIP-002-5, R1.4: and any applicable and associated Physical Control Systems, Electronic Control and Monitoring Systems and Protected Cyber Assets, with additional time to comply for requirements in the same manner as those timelines specified in the section Initial Performance of Certain Periodic Requirements above. Scenario of Unplanned Changes After the Effective Date New high impact BES Cyber System Compliance Implementation 12 months 4

Scenario of Unplanned Changes After the Effective Date New medium impact BES Cyber System Newly categorized high impact BES Cyber System from medium impact BES Cyber System Newly categorized medium impact BES Cyber System Responsible entity identifies first medium impact or high impact BES Cyber System Compliance Implementation 12 months 12 months for requirements not applicable to Medium-Impact BES Cyber Systems 12 months 24 months Additional Guidance and Implementation Time Periods for Disaster Recovery A special case of restoration as part of a disaster recovery situation (such as storm restoration) shall follow the emergency provisions of the Responsible Entity s policy required by CIP-003-5, R1. Applicability Reference Tables The rationale for this is that the primary task following a disaster is the restoration of the power system and the ability to serve customer Load. Cyber security provisionstables are implemented to support reliability and operations. If restoration were to be slowed to ensure full compliance with provided as a convenient reference to show which requirements in the Version 5 CIP Cyber Security Standards, restoration could be hampered and reliability could be harmed. However, following the completion of the restoration activities, the entity is obligated to comply with the Version 5 CIP Cyber Security Standards at the restored Facilities, and be able to demonstrate full compliance in a spotcheck or audit; or file a self-report of non-compliance with a mitigation plan describing how and when full compliance will be achieved. The following security requirements in CIP-003 through CIP-011 apply to these Associated Electronic Control or Monitoring Systems, Physical Control Systems, and Protectedspecific Cyber Assets. 5

CIP-004-5 R2 Cyber Security Training Program Associated Electronic Control or Monitoring Systems CIP-004-5 R3 Cyber Security Training CIP-004-5 R4R3 CIP-004-5 R5 CIP-004-5 R6R4 CIP-004-5 R7R5 CIP-005-5 R1 Part 1.2 CIP-005-5 R2 Personnel Risk Assessment Program Personnel Risk Assessment Management Program Revocation Electronic Security Perimeter Remote Management Physical Control System CIP-006-5 R1 Physical Security Plan CIP-006-5 R2 Visitor Control Program CIP-006-5 R3 Maintenance and Testing Program CIP-007-5 R1 Ports and Services CIP-007-5 R2 CIP-007-5 R3 Security Patch Management Malicious Code Prevention CIP-007-5 R4 Security Event Monitoring CIP-007-5 R5 System Control CIP-010-1 R1 Configuration Change Protected Cyber Assets 6

Management Associated Electronic Control or Monitoring Systems Physical Control System CIP-010-1 R2 Configuration Monitoring CIP-010-1 R3 Vulnerability Assessments CIP-011-1 R1 Information Protection CIP-011-1 R2 BES Cyber Asset Reuse and Disposal Protected Cyber Assets 7