Friday, January 21, 2022

Review - NERC-CIP and Internal Network Monitoring

Yesterday the Federal Energy Regulatory Commission (FERC) published a notice of proposed rulemaking (NOPR in the FERC jargon) on their website for “Internal Network Security Monitoring for High and Medium Impact Bulk Electric System Cyber Systems”. In this NOPR, FERC proposes to direct the North American Energy Reliability Corporation (NERC) to “to develop and submit for Commission approval new or modified Reliability Standards that require internal network security monitoring within a trusted Critical Infrastructure Protection networked environment for high and medium impact Bulk Electric System Cyber Systems.”

NOTE: Thanks to Patrick C Miller, Ampere Industrial Security [company name and link added, 8-11-22 13:24 EDT] for pointing out this NOPR on TWITTER®.

Seeking Public Comments

FERC is soliciting public comments on this NOPR. Comments may be submitted via the eFile option on for registered individuals (Docket # RM22-3-000). Others may send comments via snail mail to:

Federal Energy Regulatory Commission

Office of the Secretary

888 First Street NE

Washington, DC  20426

The deadline for submission of comments will be 60-days after the NOPR is published in the Federal Register, probably sometime next week.


This proposed expansion of cybersecurity regulations should surprise no one. It does not appear to me to be the least bit unreasonable. I would hope that most organizations under the NERC CIP would have at least some level of view within their networks that would form part of the proposed INSM, so that this proposed requirement should not be too much of a new regulatory burden.

This rulemaking is targeted at the physical operations networks supporting the BES, but other organizations utilizing similar networks to conduct operations in the physical realm should take a hard look at the proposals in the NOPR as similar technology is necessary to protect operations technology in other industries as well.

For more details about the NOPR, see my article at CFSN Detailed Analysis - - subscription required.

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