Market Participant Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS

Market Participant Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Market Participant Consultation Draft
2013-12-12
Consultation on Proposed New Critical Infrastructure Protection (“CIP”) Alberta Reliability Standards Terms and Definitions (“proposed CIP ARS Terms and Definitions”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2014/02/07
2013/12/12
Comments From:
Encana Power and Processing ULC
Date [yyyy/mm/dd]:
2014/02/04
through
2014/02/07
Contact:
Kent Lindholm
Phone:
403-901-1081
E-mail:
[email protected]
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
adverse
reliability
impact
The impact of an event that
results in frequency-related
instability; unplanned tripping
of load or generation; or
uncontrolled separation or
cascading outages that affects
a widespread area of the
Interconnection.
the impact of an event that results
in frequency-related instability;
unplanned tripping of load or
generation; or uncontrolled
separation or cascading outages
that affects a widespread area of
the Interconnection.
BES cyber
asset
A Cyber Asset that if rendered
unavailable, degraded, or
misused would, within 15
minutes of its required
operation, misoperation, or
non-operation, adversely
impact one or more Facilities,
systems, or equipment, which,
if destroyed, degraded, or
otherwise rendered
unavailable when needed,
a cyber asset that if rendered
unavailable, degraded, or misused
would, within 15 minutes of its
required operation, misoperation, or
non-operation, adversely impact
one or more facilities, systems, or
equipment, which, if destroyed,
degraded, or otherwise rendered
unavailable when needed, would
affect the reliable operation of the
bulk electric system. Redundancy
of affected facilities, systems, and
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
Thethe impact of an event that
results in frequency-related
instability; unplanned tripping of
load or generation; or
uncontrolled separation or
cascading outages that affects a
widespread area of the
Interconnection.
Market Participant Comments
and/or Alternate Proposal
AESO Reply
AESO Reply # 1: AESO to provide
A Cyber Asseta cyber asset that
if rendered unavailable,
degraded, or misused would,
within 15 minutes of its required
operation, misoperation, or nonoperation, adversely impact one
or more Facilitiesfacilities,
systems, or equipment, which, if
destroyed, degraded, or
otherwise rendered unavailable
when needed, would affect the
reliable operation of the Bulk
Page 1 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
would affect the reliable
operation of the Bulk Electric
System. Redundancy of
affected Facilities, systems,
and equipment shall not be
considered when determining
adverse impact. Each BES
Cyber Asset is included in one
or more BES Cyber Systems.
(A Cyber Asset is not a BES
Cyber Asset if, for 30
consecutive calendar days or
less, it is directly connected to
a network within an ESP, a
Cyber Asset within an ESP, or
to a BES Cyber Asset, and it is
used for data transfer,
vulnerability assessment,
maintenance, or
troubleshooting purposes.)
equipment shall not be considered
when determining adverse impact.
Each BES cyber asset is included
in one or more BES cyber
systems. (A cyber asset is not a
BES cyber asset if, for 30
consecutive days or less, it is
directly connected to a network
within an electronic security
perimeter, a cyber asset within an
electronic security perimeter, or
to a BES cyber asset, and it is
used for data transfer, vulnerability
assessment, maintenance, or
troubleshooting purposes.)
BES cyber
system
One or more BES Cyber
Assets logically grouped by a
responsible entity to perform
one or more reliability tasks for
a functional entity.
one or more BES cyber assets
logically grouped to perform one or
more reliability tasks for a functional
entity.
BES cyber
system
information
Information about the BES
Cyber System that could be
used to gain unauthorized
access or pose a security
threat to the BES Cyber
System. BES Cyber System
Information does not include
individual pieces of information
information about the BES cyber
system that could be used to gain
unauthorized access or pose a
security threat to the BES cyber
system. BES cyber system
information does not include
individual pieces of information that
by themselves do not pose a threat
or could not be used to allow
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
Electric System.bulk electric
system. Redundancy of affected
Facilitiesfacilities, systems, and
equipment shall not be
considered when determining
adverse impact. Each BES Cyber
Assetcyber asset is included in
one or more BES Cyber
Systems.cyber systems. (A
Cyber Assetcyber asset is not a
BES Cyber Assetcyber asset if,
for 30 consecutive calendar days
or less, it is directly connected to
a network within an
ESPelectronic security
perimeter, a Cyber Assetcyber
asset within an ESPelectronic
security perimeter, or to a BES
Cyber Assetcyber asset, and it is
used for data transfer,
vulnerability assessment,
maintenance, or troubleshooting
purposes.)
Oneone or more BES Cyber
Assetscyber assets logically
grouped by a responsible entity to
perform one or more reliability
tasks for a functional entity.
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Informationinformation about the
BES Cyber Systemcyber system
that could be used to gain
unauthorized access or pose a
security threat to the BES Cyber
Systemcyber system. BES
Cyber System Informationcyber
system information does not
include individual pieces of
Page 2 of 9
Proposed CIP ARS Terms and Definitions
Term
blackstart
resource
NERC Definition
Proposed Alberta Definition
that by themselves do not
pose a threat or could not be
used to allow unauthorized
access to BES Cyber
Systems, such as, but not
limited to, device names,
individual IP addresses without
context, ESP names, or policy
statements. Examples of BES
Cyber System Information may
include, but are not limited to,
security procedures or security
information about BES Cyber
Systems, Physical Access
Control Systems, and
Electronic Access Control or
Monitoring Systems that is not
publicly available and could be
used to allow unauthorized
access or unauthorized
distribution; collections of
network addresses; and
network topology of the BES
Cyber System.
unauthorized access to BES cyber
systems, such as, but not limited
to, device names, individual IP
addresses without context,
electronic security perimeter
names, or policy statements.
A generating unit(s) and its
associated set of equipment
which has the ability to be
started without support from
the System or is designed to
remain energized without
connection to the remainder of
the System, with the ability to
energize a bus, meeting the
Transmission Operator’s
restoration plan needs for real
and reactive power capability,
frequency and voltage control,
a generating unit or aggregated
generating facility and its
associated set of equipment which
has the ability to be started without
support from the system or is
designed to remain energized
without connection to the remainder
of the system, with the ability to
energize a dead bus, meeting the
restoration plan needs for real
power and reactive power
capability, frequency and voltage
control, and that has been included
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
information that by themselves do
not pose a threat or could not be
used to allow unauthorized
access to BES Cyber
Systemscyber systems, such as,
but not limited to, device names,
individual IP addresses without
context, ESPelectronic security
perimeter names, or policy
statements. Examples of BES
Cyber System Information may
include, but are not limited to,
security procedures or security
information about BES Cyber
Systems, Physical Access Control
Systems, and Electronic Access
Control or Monitoring Systems
that is not publicly available and
could be used to allow
unauthorized access or
unauthorized distribution;
collections of network addresses;
and network topology of the BES
Cyber System.
Aa generating unit(s) or
aggregated generating facility
and its associated set of
equipment which has the ability to
be started without support from
the Systemsystem or is designed
to remain energized without
connection to the remainder of
the Systemsystem, with the ability
to energize a dead bus, meeting
the Transmission Operator’s
restoration plan needs for real
power and reactive power
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Page 3 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
and that has been included in
the Transmission Operator’s
restoration plan.
in the restoration plan.
CIP
exceptional
circumstance
A situation that involves or
threatens to involve one or
more of the following, or
similar, conditions that impact
safety or BES reliability: a risk
of injury or death; a natural
disaster; civil unrest; an
imminent or existing hardware,
software, or equipment failure;
a Cyber Security Incident
requiring emergency
assistance; a response by
emergency services; the
enactment of a mutual
assistance agreement; or an
impediment of large scale
workforce availability.
a situation that involves or threatens
to involve one or more of the
following, or similar, conditions that
impact safety or bulk electric
system reliability: a risk of injury or
death; a natural disaster; civil
unrest; an imminent or existing
hardware, software, or equipment
failure; a cyber security incident
requiring emergency assistance; a
response by emergency services;
the enactment of a mutual
assistance agreement; or an
impediment of large scale workforce
availability.
CIP senior
manager
A single senior management
official with overall authority
and responsibility for leading
and managing implementation
of and continuing adherence to
the requirements within the
NERC CIP Standards, CIP002 through CIP-011.
a single senior management official
with overall authority and
responsibility for leading and
managing implementation of and
continuing adherence to the
requirements within the CIP
reliability standards, CIP-002
through CIP-011.
control centre
One or more facilities hosting
operating personnel that
monitor and control the Bulk
Electric System (BES) in realtime to perform the reliability
tasks, including their
one or more facilities hosting
operating personnel that monitor
and control the bulk electric
system in real-time to perform the
reliability tasks, including their
associated data centers, of: 1) the
ISO, 2) an operator of a
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
capability, frequency and voltage
control, and that has been
included in the Transmission
Operator’s restoration plan.
Aa situation that involves or
threatens to involve one or more
of the following, or similar,
conditions that impact safety or
BESbulk electric system
reliability: a risk of injury or death;
a natural disaster; civil unrest; an
imminent or existing hardware,
software, or equipment failure; a
Cyber Security Incidentcyber
security incident requiring
emergency assistance; a
response by emergency services;
the enactment of a mutual
assistance agreement; or an
impediment of large scale
workforce availability.
Aa single senior management
official with overall authority and
responsibility for leading and
managing implementation of and
continuing adherence to the
requirements within the NERC
CIP Standardsreliability
standards, CIP-002 through CIP011.
Oneone or more facilities hosting
operating personnel that monitor
and control the Bulk Electric
System (BES)bulk electric
system in real-time to perform
the reliability tasks, including their
associated data centers, of: 1) a
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Comment # 1 :
It is Encana’s understanding
that the ‘control center’
definition would not apply to a
control room of a transmission
facility that radially connects a
single generating facility to the
Page 4 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
associated data centers, of: 1)
a Reliability Coordinator, 2) a
Balancing Authority, 3) a
Transmission Operator for
transmission Facilities at two
or more locations, or 4) a
Generator Operator for
generation Facilities at two or
more locations.
transmission facility for
transmission facilities at two or
more locations, or 3) an operator of
a generating unit or an operator
of an aggregated generating
facility for generating units or
aggregated generating facilities
at two or more locations.
cranking path
A portion of the electric system
that can be isolated and then
energized to deliver electric
power from a generation
source to enable the startup of
one or more other generating
units.
a portion of the electric system that
can be isolated and then energized
to deliver electric power from a
generation source to enable the
startup of one or more other
generating units or aggregated
generating facilities.
cyber asset
Programmable electronic
devices, including the
hardware, software, and data
in those devices.
programmable electronic devices,
including the hardware, software,
and data in those devices.
cyber security
incident
A malicious act or suspicious
event that:
• Compromises, or was an
attempt to compromise, the
Electronic Security Perimeter
or Physical Security Perimeter
or,
• Disrupts, or was an attempt
to disrupt, the operation of a
BES Cyber System.
a malicious act or suspicious event
that:
• compromises, or was an attempt
to compromise, the electronic
security perimeter or physical
security perimeter or,
• disrupts, or was an attempt to
disrupt, the operation of a BES
cyber system.
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
Reliability Coordinatorthe ISO, 2)
a Balancing Authority, 3) a
Transmission Operatoran
operator of a transmission
facility for transmission
Facilitiesfacilities at two or more
locations, or 4) a Generator
Operator3) an operator of a
generating unit or an operator
of an aggregated generating
facility for generation
Facilitiesgenerating units or
aggregated generating facilities
at two or more locations.
Aa portion of the electric system
that can be isolated and then
energized to deliver electric
power from a generation source
to enable the startup of one or
more other generating units. or
aggregated generating
facilities.
Programmableprogrammable
electronic devices, including the
hardware, software, and data in
those devices.
Market Participant Comments
and/or Alternate Proposal
AESO Reply
BES. Likewise, it is Encana’s
understanding that the ‘control
center’ definition would not
apply to the control room of a
single generating facility.
Please clarify that this is the
intent of the ‘control center’
definition.
Comment # 2 :
Please clarify the requirements
for establishing ‘cranking paths’
within the Alberta BES.
Aa malicious act or suspicious
event that:
• Compromisescompromises, or
was an attempt to compromise,
the Electronic Security
Perimeterelectronic security
perimeter or Physical Security
Perimeterphysical security
perimeter or,
• Disruptsdisrupts, or was an
Page 5 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
dial-up
connectivity
A data communication link that
is established when the
communication equipment
dials a phone number and
negotiates a connection with
the equipment on the other
end of the link.
a data communication link that is
established when the
communication equipment dials a
phone number and negotiates a
connection with the equipment on
the other end of the link.
electronic
access control
or monitoring
systems
Cyber Assets that perform
electronic access control or
electronic access monitoring of
the Electronic Security
Perimeter(s) or BES Cyber
Systems. This includes
Intermediate Devices.
cyber assets that perform
electronic access control or
electronic access monitoring of the
electronic security perimeter(s) or
BES cyber systems. This includes
intermediate systems.
electronic
access point
A Cyber Asset interface on an
Electronic Security Perimeter
that allows routable
communication between Cyber
Assets outside an Electronic
Security Perimeter and Cyber
Assets inside an Electronic
Security Perimeter.
a cyber asset interface on an
electronic security perimeter that
allows routable communication
between cyber assets outside an
electronic security perimeter and
cyber assets inside an electronic
security perimeter.
electronic
security
perimeter
The logical border surrounding
a network to which BES Cyber
Systems are connected using
a routable protocol.
the logical border surrounding a
network to which BES cyber
systems are connected using a
routable protocol.
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
attempt to disrupt, the operation
of a BES Cyber Systemcyber
system.
Aa data communication link that
is established when the
communication equipment dials a
phone number and negotiates a
connection with the equipment on
the other end of the link.
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Cyber Assetscyber assets that
perform electronic access control
or electronic access monitoring of
the Electronic Security
Perimeterelectronic security
perimeter(s) or BES Cyber
Systems.cyber systems. This
includes Intermediate
Devicesintermediate systems.
A Cyber Asseta cyber asset
interface on an Electronic
Security Perimeterelectronic
security perimeter that allows
routable communication between
Cyber Assetscyber assets
outside an Electronic Security
Perimeterelectronic security
perimeter and Cyber
Assetscyber assets inside an
Electronic Security
Perimeterelectronic security
perimeter.
Thethe logical border surrounding
a network to which BES Cyber
Systemscyber systems are
connected using a routable
protocol.
Page 6 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
external
routable
connectivity
The ability to access a BES
Cyber System from a Cyber
Asset that is outside of its
associated Electronic Security
Perimeter via a bi-directional
routable protocol connection.
the ability to access a BES cyber
system from a cyber asset that is
outside of its associated electronic
security perimeter via a bidirectional routable protocol
connection.
interactive
remote access
User-initiated access by a
person employing a remote
access client or other remote
access technology using a
routable protocol. Remote
access originates from a
Cyber Asset that is not an
Intermediate Device and not
located within any of the
Responsible Entity’s Electronic
Security Perimeter(s) or at a
defined Electronic Access
Point (EAP). Remote access
may be initiated from: 1) Cyber
Assets used or owned by the
Responsible Entity, 2) Cyber
Assets used or owned by
employees, and 3) Cyber
Assets used or owned by
vendors, contractors, or
consultants. Interactive remote
access does not include
system-to-system process
communications.
user-initiated access by a person
employing a remote access client or
other remote access technology
using a routable protocol. Remote
access originates from a cyber
asset that is not an intermediate
system and not located within any
of the Responsible Entity’s
electronic security perimeter(s) or
at a defined electronic access
point. Remote access may be
initiated from: 1) cyber assets used
or owned by the Responsible Entity,
2) cyber assets used or owned by
employees, and 3) cyber assets
used or owned by vendors,
contractors, or consultants.
Interactive remote access does
not include system-to-system
process communications.
Issued for Market Participant Consultation: 2013-12-12
Note: the “Responsible Entity”
referred to in this definition is
identified in the applicability section
of each Version 5 CIP Cyber
Security reliability standard.
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
Thethe ability to access a BES
Cyber Systemcyber system from
a Cyber Assetcyber asset that is
outside of its associated
Electronic Security
Perimeterelectronic security
perimeter via a bi-directional
routable protocol connection.
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Useruser-initiated access by a
person employing a remote
access client or other remote
access technology using a
routable protocol. Remote access
originates from a Cyber
Assetcyber asset that is not an
Intermediate Deviceintermediate
system and not located within
any of the Responsible Entity’s
Electronic Security
Perimeterelectronic security
perimeter(s) or at a defined
Electronic Access Point
(EAP).electronic access point.
Remote access may be initiated
from: 1) Cyber Assetscyber
assets used or owned by the
Responsible Entity, 2) Cyber
Assetscyber assets used or
owned by employees, and 3)
Cyber Assetscyber assets used
or owned by vendors, contractors,
or consultants. Interactive
remote access does not include
system-to-system process
communications.
Page 7 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
intermediate
system
A Cyber Asset or collection of
Cyber Assets performing
access control to restrict
Interactive Remote Access to
only authorized users. The
Intermediate System must not
be located inside the
Electronic Security Perimeter.
a cyber asset or collection of cyber
assets performing access control to
restrict interactive remote access
to only authorized users. The
intermediate system must not be
located inside the electronic
security perimeter.
physical
access control
systems
Cyber Assets that control,
alert, or log access to the
Physical Security Perimeter(s),
exclusive of locally mounted
hardware or devices at the
Physical Security Perimeter
such as motion sensors,
electronic lock control
mechanisms, and badge
readers.
cyber assets that control, alert, or
log access to the physical security
perimeter(s), exclusive of locally
mounted hardware or devices at the
physical security perimeter such
as motion sensors, electronic lock
control mechanisms, and badge
readers.
physical
security
perimeter
The physical border
surrounding locations in which
BES Cyber Assets, BES Cyber
Systems, or Electronic Access
Control or Monitoring Systems
reside, and for which access is
controlled.
the physical border surrounding
locations in which BES cyber
assets, BES cyber systems, or
electronic access control or
monitoring systems reside, and
for which access is controlled.
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
Note: the “Responsible Entity”
referred to in this definition is
identified in the applicability
section of each Version 5 CIP
Cyber Security reliability
standard.
A Cyber Asseta cyber asset or
collection of Cyber Assetscyber
assets performing access control
to restrict Interactive Remote
Accessinteractive remote
access to only authorized users.
The Intermediate
Systemintermediate system
must not be located inside the
Electronic Security
Perimeterelectronic security
perimeter.
Cyber Assetscyber assets that
control, alert, or log access to the
Physical Security
Perimeterphysical security
perimeter(s), exclusive of locally
mounted hardware or devices at
the Physical Security
Perimeterphysical security
perimeter such as motion
sensors, electronic lock control
mechanisms, and badge readers.
Thethe physical border
surrounding locations in which
BES Cyber Assetscyber assets,
BES Cyber Systemscyber
systems, or Electronic Access
Controlelectronic access
control or Monitoring
Systemsmonitoring systems
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Page 8 of 9
Proposed CIP ARS Terms and Definitions
Term
NERC Definition
Proposed Alberta Definition
protected
cyber assets
One or more Cyber Assets
connected using a routable
protocol within or on an
Electronic Security Perimeter
that is not part of the highest
impact BES Cyber System
within the same Electronic
Security Perimeter. The impact
rating of Protected Cyber
Assets is equal to the highest
rated BES Cyber System in
the same ESP. A Cyber Asset
is not a Protected Cyber Asset
if, for 30 consecutive calendar
days or less, it is connected
either to a Cyber Asset within
the ESP or to the network
within the ESP, and it is used
for data transfer, vulnerability
assessment, maintenance, or
troubleshooting purposes.
one or more cyber assets
connected using a routable protocol
within or on an electronic security
perimeter that is not part of the
highest impact BES cyber system
within the same electronic
security perimeter. The impact
rating of protected cyber assets is
equal to the highest rated BES
cyber system in the same
electronic security perimeter. A
cyber asset is not a protected
cyber asset if, for 30 consecutive
days or less, it is connected either
to a cyber asset within the
electronic security perimeter or to
the network within the electronic
security perimeter, and it is used
for data transfer, vulnerability
assessment, maintenance, or
troubleshooting purposes.
reportable
cyber security
incident
A Cyber Security Incident that
has compromised or disrupted
one or more reliability tasks of
a functional entity.
a cyber security incident that has
compromised or disrupted one or
more reliability tasks of a functional
entity.
Issued for Market Participant Consultation: 2013-12-12
Blackline Comparison of the
NERC Definition and the
Proposed AESO Definition
reside, and for which access is
controlled.
Oneone or more Cyber
Assetscyber assets connected
using a routable protocol within or
on an Electronic Security
Perimeterelectronic security
perimeter that is not part of the
highest impact BES Cyber
Systemcyber system within the
same Electronic Security
Perimeter.electronic security
perimeter. The impact rating of
Protected Cyber Assetsprotected
cyber assets is equal to the
highest rated BES Cyber
Systemcyber system in the
same ESP.electronic security
perimeter. A Cyber Assetcyber
asset is not a Protected Cyber
Assetprotected cyber asset if,
for 30 consecutive calendar days
or less, it is connected either to a
Cyber Assetcyber asset within
the ESPelectronic security
perimeter or to the network within
the ESPelectronic security
perimeter, and it is used for data
transfer, vulnerability assessment,
maintenance, or troubleshooting
purposes.
A Cyber Security Incidenta cyber
security incident that has
compromised or disrupted one or
more reliability tasks of a
functional entity.
Market Participant Comments
and/or Alternate Proposal
AESO Reply
Page 9 of 9