CIP 002 5.1a
CIP 002 5.1a
CIP 002 5.1a
A. Introduction
1. Title: Cyber Security — BES Cyber System Categorization
2. Number: CIP-002-5.1a
3. Purpose: To identify and categorize 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. Identification and categorization of
BES Cyber Systems support appropriate protection against compromises that could
lead to misoperation or instability in the BES.
4. Applicability:
4.1. Functional Entities: For the purpose of the requirements contained herein, the
following list of functional entities will be collectively referred to as “Responsible
Entities.” For requirements in this standard where a specific functional entity or
subset of functional entities are the applicable entity or entities, the functional entity
or entities are specified explicitly.
4.1.1. Balancing Authority
4.1.2. Distribution Provider that owns one or more of the following Facilities, systems,
and equipment for the protection or restoration of the BES:
4.1.2.1. Each underfrequency load shedding (UFLS) or undervoltage load shedding
(UVLS) system that:
4.1.2.1.1. is part of a Load shedding program that is subject to one or more
requirements in a NERC or Regional Reliability Standard; and
4.1.2.1.2. performs automatic Load shedding under a common control system
owned by the Responsible Entity, without human operator initiation,
of 300 MW or more.
4.1.2.2. Each Special Protection System or Remedial Action Scheme where the
Special Protection System or Remedial Action Scheme is subject to one or
more requirements in a NERC or Regional Reliability Standard.
4.1.2.3. Each Protection System (excluding UFLS and UVLS) that applies to
Transmission where the Protection System is subject to one or more
requirements in a NERC or Regional Reliability Standard.
4.1.2.4. Each Cranking Path and group of Elements meeting the initial switching
requirements from a Blackstart Resource up to and including the first
interconnection point of the starting station service of the next generation
unit(s) to be started.
4.1.3. Generator Operator
4.1.4. Generator Owner
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
4.2.3.3. The systems, structures, and components that are regulated by the Nuclear
Regulatory Commission under a cyber security plan pursuant to 10 C.F.R.
Section 73.54.
4.2.3.4. For Distribution Providers, the systems and equipment that are not included
in section 4.2.1 above.
5. Effective Dates:
1. 24 Months Minimum – CIP-002-5.1a 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.
2. In those jurisdictions where no regulatory approval is required CIP-002-5.1a shall
become effective on the first day of the ninth calendar quarter following Board
of Trustees’ approval, or as otherwise made effective pursuant to the laws
applicable to such ERO governmental authorities.
6. Background:
This standard provides “bright-line” criteria for applicable Responsible Entities to
categorize their BES Cyber Systems based on the impact of their associated Facilities,
systems, and equipment, which, if destroyed, degraded, misused, or otherwise
rendered unavailable, would affect the reliable operation of the Bulk Electric System.
Several concepts provide the basis for the approach to the standard.
Throughout the standards, unless otherwise stated, bulleted items in the
requirements are items that are linked with an “or,” and numbered items are items
that are linked with an “and.”
Many references in the Applicability section and the criteria in Attachment 1 of CIP-
002 use a threshold of 300 MW for UFLS and UVLS. This particular threshold of 300
MW for UVLS and UFLS was provided in Version 1 of the CIP Cyber Security
Standards. The threshold remains at 300 MW since it is specifically addressing UVLS
and UFLS, which are last ditch efforts to save the Bulk Electric System. A review of
UFLS tolerances defined within regional reliability standards for UFLS program
requirements to date indicates that the historical value of 300 MW represents an
adequate and reasonable threshold value for allowable UFLS operational tolerances.
BES Cyber Systems
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 drafting team’s 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.
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
CCA
CCA
CCA
CCA
Associated
Protected Cyber
Assets
Non-Critical
Non-Critical Cyber
Cyber Asset
Asset
Within
Within anan ESP
ESP
Associated
Electronic and
Physical Access
Control and
Monitoring
Systems
CIP-005-4 R1.5 and
CIP-006-4 R2
In transitioning from Version 4 to Version 5, a BES Cyber System can be viewed simply
as a grouping of Critical Cyber Assets (as that term is used in Version 4). The CIP Cyber
Security Standards use the “BES Cyber System” term primarily to provide a higher level
for referencing the object of a requirement. For example, it becomes possible to
apply requirements dealing with recovery and malware protection to a grouping
rather than individual Cyber Assets, and it becomes clearer in the requirement that
malware protection applies to the system as a whole and may not be necessary for
every individual device to comply.
Another reason for using the term “BES Cyber System” is to provide a convenient level
at which a Responsible Entity can organize their documented implementation of the
requirements and compliance evidence. Responsible Entities can use the well-
developed concept of a security plan for each BES Cyber System to document the
programs, processes, and plans in place to comply with security requirements.
It is left up to the Responsible Entity to determine the level of granularity at which to
identify a BES Cyber System within the qualifications in the definition of BES Cyber
System. For example, the Responsible Entity might choose to view an entire plant
control system as a single BES Cyber System, or it might choose to view certain
components of the plant control system as distinct BES Cyber Systems. The
Responsible Entity should take into consideration the operational environment and
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
scope of management when defining the BES Cyber System boundary in order to
maximize efficiency in secure operations. Defining the boundary too tightly may result
in redundant paperwork and authorizations, while defining the boundary too broadly
could make the secure operation of the BES Cyber System difficult to monitor and
assess.
Reliable Operation of the BES
The scope of the CIP Cyber Security Standards is restricted to BES Cyber Systems that
would impact the reliable operation of the BES. In order to identify BES Cyber
Systems, Responsible Entities determine whether the BES Cyber Systems perform or
support any BES reliability function according to those reliability tasks identified for
their reliability function and the corresponding functional entity’s responsibilities as
defined in its relationships with other functional entities in the NERC Functional
Model. This ensures that the initial scope for consideration includes only those BES
Cyber Systems and their associated BES Cyber Assets that perform or support the
reliable operation of the BES. The definition of BES Cyber Asset provides the basis for
this scoping.
Real-time Operations
One characteristic of the BES Cyber Asset is a real-time scoping characteristic. The
time horizon that is significant for BES Cyber Systems and BES Cyber Assets subject to
the application of these Version 5 CIP Cyber Security Standards is defined as that
which is material to real-time operations for the reliable operation of the BES. To
provide a better defined time horizon than “Real-time,” BES Cyber Assets are those
Cyber Assets that, if rendered unavailable, degraded, or misused, would adversely
impact the reliable operation of the BES within 15 minutes of the activation or
exercise of the compromise. This time window must not include in its consideration
the activation of redundant BES Cyber Assets or BES Cyber Systems: from the cyber
security standpoint, redundancy does not mitigate cyber security vulnerabilities.
Categorization Criteria
The criteria defined in Attachment 1 are used to categorize BES Cyber Systems into
impact categories. Requirement 1 only requires the discrete identification of BES
Cyber Systems for those in the high impact and medium impact categories. All BES
Cyber Systems for Facilities not included in Attachment 1 – Impact Rating Criteria,
Criteria 1.1 to 1.4 and Criteria 2.1 to 2.11 default to be low impact.
This general process of categorization of BES Cyber Systems based on impact on the
reliable operation of the BES is consistent with risk management approaches for the
purpose of application of cyber security requirements in the remainder of the Version
5 CIP Cyber Security Standards.
Electronic Access Control or Monitoring Systems, Physical Access Control Systems,
and Protected Cyber Assets that are associated with BES Cyber Systems
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
BES Cyber Systems have associated Cyber Assets, which, if compromised, pose a
threat to the BES Cyber System by virtue of: (a) their location within the Electronic
Security Perimeter (Protected Cyber Assets), or (b) the security control function they
perform (Electronic Access Control or Monitoring Systems and Physical Access Control
Systems). These Cyber Assets include:
Electronic Access Control or Monitoring Systems (“EACMS”) – Examples include:
Electronic Access Points, Intermediate Systems, authentication servers (e.g.,
RADIUS servers, Active Directory servers, Certificate Authorities), security event
monitoring systems, and intrusion detection systems.
Physical Access Control Systems (“PACS”)– Examples include: authentication
servers, card systems, and badge control systems.
Protected Cyber Assets (“PCA”) – Examples may include, to the extent they are
within the ESP: file servers, ftp servers, time servers, LAN switches, networked
printers, digital fault recorders, and emission monitoring systems.
R1. Each Responsible Entity shall implement a process that considers each of the
following assets for purposes of parts 1.1 through 1.3: [Violation Risk Factor:
High][Time Horizon: Operations Planning]
i.Control Centers and backup Control Centers;
ii.Transmission stations and substations;
iii.Generation resources;
iv.Systems and facilities critical to system restoration, including Blackstart
Resources and Cranking Paths and initial switching requirements;
v.Special Protection Systems that support the reliable operation of the Bulk
Electric System; and
vi.For Distribution Providers, Protection Systems specified in Applicability
section 4.2.1 above.
1.1. Identify each of the high impact BES Cyber Systems according to
Attachment 1, Section 1, if any, at each asset;
1.2. Identify each of the medium impact BES Cyber Systems according to
Attachment 1, Section 2, if any, at each asset; and
1.3. Identify each asset that contains a low impact BES Cyber System
according to Attachment 1, Section 3, if any (a discrete list of low impact
BES Cyber Systems is not required).
M1. Acceptable evidence includes, but is not limited to, dated electronic or physical lists
required by Requirement R1, and Parts 1.1 and 1.2.
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
R2. The Responsible Entity shall: [Violation Risk Factor: Lower] [Time Horizon: Operations
Planning]
2.1 Review the identifications in Requirement R1 and its parts (and update
them if there are changes identified) at least once every 15 calendar
months, even if it has no identified items in Requirement R1, and
2.2 Have its CIP Senior Manager or delegate approve the identifications
required by Requirement R1 at least once every 15 calendar months,
even if it has no identified items in Requirement R1.
M2. Acceptable evidence includes, but is not limited to, electronic or physical dated
records to demonstrate that the Responsible Entity has reviewed and updated, where
necessary, the identifications required in Requirement R1 and its parts, and has had its
CIP Senior Manager or delegate approve the identifications required in Requirement
R1 and its parts at least once every 15 calendar months, even if it has none identified
in Requirement R1 and its parts, as required by Requirement R2.
C. Compliance
1. Compliance Monitoring Process:
1.1. Compliance Enforcement Authority:
The Regional Entity shall serve as the Compliance Enforcement Authority (“CEA”)
unless the applicable entity is owned, operated, or controlled by the Regional
Entity. In such cases the ERO or a Regional Entity approved by FERC or other
applicable governmental authority shall serve as the CEA.
1.2. Evidence Retention:
The following evidence retention periods identify the period of time an entity is
required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the CEA may ask an entity to provide other evidence to show
that it was compliant for the full time period since the last audit.
The Responsible Entity shall keep data or evidence to show compliance as
identified below unless directed by its CEA to retain specific evidence for a
longer period of time as part of an investigation:
Each Responsible Entity shall retain evidence of each requirement in this
standard for three calendar years.
If a Responsible Entity is found non-compliant, it shall keep information
related to the non-compliance until mitigation is complete and approved or
for the time specified above, whichever is longer.
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The CEA shall keep the last audit records and all requested and submitted
subsequent audit records.
1.3. Compliance Monitoring and Assessment Processes:
Compliance Audit
Self-Certification
Spot Checking
Compliance Investigation
Self-Reporting
Complaint
1.4. Additional Compliance Information
None
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
R2 Operations Lower The Responsible Entity The Responsible Entity The Responsible Entity The Responsible Entity
Planning did not complete its did not complete its did not complete its did not complete its
review and update for review and update for review and update for review and update for
the identification the identification the identification the identification
required for R1 within required for R1 within required for R1 within required for R1 within
15 calendar months 16 calendar months 17 calendar months 18 calendar months of
but less than or equal but less than or equal but less than or equal the previous review.
to 16 calendar months to 17 calendar months to 18 calendar months (R2.1)
of the previous review. of the previous review. of the previous review. OR
(R2.1) (R2.1) (R2.1)
The Responsible Entity
OR OR OR failed to complete its
The Responsible Entity The Responsible Entity The Responsible Entity approval of the
did not complete its failed to complete its failed to complete its identifications
approval of the approval of the approval of the required by R1 by the
identifications identifications identifications CIP Senior Manager or
required by R1 by the required by R1 by the required by R1 by the delegate according to
CIP Senior Manager or CIP Senior Manager or CIP Senior Manager or Requirement R2 within
delegate according to delegate according to delegate according to 18 calendar months of
Requirement R2 within Requirement R2 within Requirement R2 within the previous approval.
15 calendar months 16 calendar months 17 calendar months (R2.2)
but less than or equal but less than or equal but less than or equal
to 16 calendar months to 17 calendar months to 18 calendar months
of the previous of the previous of the previous
approval. (R2.2) approval. (R2.2) approval. (R2.2)
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
D. Regional Variances
None.
E. Interpretations
None.
F. Associated Documents
None.
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CIP-002-5.1a - Attachment 1
1.1. Each Control Center or backup Control Center used to perform the functional
obligations of the Reliability Coordinator.
1.2. Each Control Center or backup Control Center used to perform the functional
obligations of the Balancing Authority: 1) for generation equal to or greater than an
aggregate of 3000 MW in a single Interconnection, or 2) for one or more of the assets
that meet criterion 2.3, 2.6, or 2.9.
1.3. Each Control Center or backup Control Center used to perform the functional
obligations of the Transmission Operator for one or more of the assets that meet
criterion 2.2, 2.4, 2.5, 2.7, 2.8, 2.9, or 2.10.
1.4 Each Control Center or backup Control Center used to perform the functional
obligations of the Generator Operator for one or more of the assets that meet
criterion 2.1, 2.3, 2.6, or 2.9.
Each BES Cyber System, not included in Section 1 above, associated with any of the following:
2.1. Commissioned generation, by each group of generating units at a single plant location,
with an aggregate highest rated net Real Power capability of the preceding 12
calendar months equal to or exceeding 1500 MW in a single Interconnection. For each
group of generating units, the only BES Cyber Systems that meet this criterion are
those shared BES Cyber Systems that could, within 15 minutes, adversely impact the
reliable operation of any combination of units that in aggregate equal or exceed 1500
MW in a single Interconnection.
2.2. Each BES reactive resource or group of resources at a single location (excluding
generation Facilities) with an aggregate maximum Reactive Power nameplate rating of
1000 MVAR or greater (excluding those at generation Facilities). The only BES Cyber
Systems that meet this criterion are those shared BES Cyber Systems that could,
within 15 minutes, adversely impact the reliable operation of any combination of
resources that in aggregate equal or exceed 1000 MVAR.
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
2.3. Each generation Facility that its Planning Coordinator or Transmission Planner
designates, and informs the Generator Owner or Generator Operator, as necessary to
avoid an Adverse Reliability Impact in the planning horizon of more than one year.
2.4. Transmission Facilities operated at 500 kV or higher. For the purpose of this criterion,
the collector bus for a generation plant is not considered a Transmission Facility, but is
part of the generation interconnection Facility.
2.5. Transmission Facilities that are operating between 200 kV and 499 kV at a single
station or substation, where the station or substation is connected at 200 kV or higher
voltages to three or more other Transmission stations or substations and has an
"aggregate weighted value" exceeding 3000 according to the table below. The
"aggregate weighted value" for a single station or substation is determined by
summing the "weight value per line" shown in the table below for each incoming and
each outgoing BES Transmission Line that is connected to another Transmission
station or substation. For the purpose of this criterion, the collector bus for a
generation plant is not considered a Transmission Facility, but is part of the generation
interconnection Facility.
Voltage Value of a Line Weight Value per Line
less than 200 kV (not applicable) (not applicable)
200 kV to 299 kV 700
300 kV to 499 kV 1300
500 kV and above 0
2.6. Generation at a single plant location or Transmission Facilities at a single station or
substation location that are identified by its Reliability Coordinator, Planning
Coordinator, or Transmission Planner as critical to the derivation of Interconnection
Reliability Operating Limits (IROLs) and their associated contingencies.
2.7. Transmission Facilities identified as essential to meeting Nuclear Plant Interface
Requirements.
2.8. Transmission Facilities, including generation interconnection Facilities, providing the
generation interconnection required to connect generator output to the Transmission
Systems that, if destroyed, degraded, misused, or otherwise rendered unavailable,
would result in the loss of the generation Facilities identified by any Generator Owner
as a result of its application of Attachment 1, criterion 2.1 or 2.3.
2.9. Each Special Protection System (SPS), Remedial Action Scheme (RAS), or automated
switching System that operates BES Elements, that, if destroyed, degraded, misused or
otherwise rendered unavailable, would cause one or more Interconnection Reliability
Operating Limits (IROLs) violations for failure to operate as designed or cause a
reduction in one or more IROLs if destroyed, degraded, misused, or otherwise
rendered unavailable.
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CIP-002-5.1a — Cyber Security — BES Cyber System Categorization
2.10. Each system or group of Elements that performs automatic Load shedding under a
common control system, without human operator initiation, of 300 MW or more
implementing undervoltage load shedding (UVLS) or underfrequency load shedding
(UFLS) under a load shedding program that is subject to one or more requirements in
a NERC or regional reliability standard.
2.11. Each Control Center or backup Control Center, not already included in High Impact
Rating (H) above, used to perform the functional obligations of the Generator
Operator for an aggregate highest rated net Real Power capability of the preceding 12
calendar months equal to or exceeding 1500 MW in a single Interconnection.
2.12. Each Control Center or backup Control Center used to perform the functional
obligations of the Transmission Operator not included in High Impact Rating (H),
above.
2.13. Each Control Center or backup Control Center, not already included in High Impact
Rating (H) above, used to perform the functional obligations of the Balancing
Authority for generation equal to or greater than an aggregate of 1500 MW in a single
Interconnection.
BES Cyber Systems not included in Sections 1 or 2 above that are associated with any of the
following assets and that meet the applicability qualifications in Section 4 - Applicability, part
4.2 – Facilities, of this standard:
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Appendix 1
Section “4. Applicability” of the standards provides important information for Responsible
Entities to determine the scope of the applicability of the CIP Cyber Security Requirements.
Section “4.1. Functional Entities” is a list of NERC functional entities to which the standard
applies. If the entity is registered as one or more of the functional entities listed in section 4.1,
then the NERC CIP Cyber Security Standards apply. Note that there is a qualification in section
4.1 that restricts the applicability in the case of Distribution Providers to only those that own
certain types of systems and equipment listed in 4.2.
Section “4.2. Facilities” defines the scope of the Facilities, systems, and equipment owned by
the Responsible Entity, as qualified in section 4.1, that is subject to the requirements of the
standard. In addition to the set of BES Facilities, Control Centers, and other systems and
equipment, the list includes the qualified set of systems and equipment owned by Distribution
Providers. While the NERC Glossary term “Facilities” already includes the BES characteristic, the
additional use of the term BES here is meant to reinforce the scope of applicability of these
Facilities where it is used, especially in this applicability scoping section. This in effect sets the
scope of Facilities, systems, and equipment that is subject to the standards. This section is
especially significant in CIP-002-5.1a and represents the total scope of Facilities, systems, and
equipment to which the criteria in Attachment 1 apply. This is important because it determines
the balance of these Facilities, systems, and equipment that are Low Impact once those that
qualify under the High and Medium Impact categories are filtered out.
For the purpose of identifying groups of Facilities, systems, and equipment, whether by location
or otherwise, the Responsible Entity identifies assets as described in Requirement R1 of CIP-
002-5.1a. This is a process familiar to Responsible Entities that have to comply with versions 1,
2, 3, and 4 of the CIP standards for Critical Assets. As in versions 1, 2, 3, and 4, Responsible
Entities may use substations, generation plants, and Control Centers at single site locations as
identifiers of these groups of Facilities, systems, and equipment.
CIP-002-5.1a
CIP-002-5.1a requires that applicable Responsible Entities categorize their BES Cyber Systems
and associated BES Cyber Assets according to the criteria in Attachment 1. A BES Cyber Asset
includes in its definition, “…that if rendered unavailable, degraded, or misused would, within 15
minutes adversely impact the reliable operation of the BES.”
The following provides guidance that a Responsible Entity may use to identify the BES Cyber
Systems that would be in scope. The concept of BES reliability operating service is useful in
providing Responsible Entities with the option of a defined process for scoping those BES Cyber
Guidelines and Technical Basis
Systems that would be subject to CIP-002-5.1a. The concept includes a number of named BES
reliability operating services. These named services include:
Dynamic Response
The Dynamic Response Operating Service includes those actions performed by BES Elements or
subsystems which are automatically triggered to initiate a response to a BES condition. These
actions are triggered by a single element or control device or a combination of these elements
or devices in concert to perform an action or cause a condition in reaction to the triggering
action or condition. The types of dynamic responses that may be considered as potentially
having an impact on the BES are:
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Guidelines and Technical Basis
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Guidelines and Technical Basis
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Guidelines and Technical Basis
Managing Constraints
Managing Constraints includes activities, actions and conditions that are necessary to ensure
that elements of the BES operate within design limits and constraints established for the
reliability and operability of the BES. Aspects of the Managing Constraints include, but are not
limited to:
Available Transfer Capability (ATC) (TOP)
Interchange schedules (TOP, RC)
Generation re-dispatch and unit commit (GOP)
Identify and monitor SOL’s & IROL’s (TOP, RC)
Identify and monitor Flow gates (TOP, RC)
Restoration of BES
The Restoration of BES Operations Service includes activities, actions and conditions necessary
to go from a shutdown condition to an operating condition delivering electric power without
external assistance. Aspects of the Restoration of BES function include, but are not limited to:
Restoration including planned cranking path
Through black start units (TOP, GOP)
Through tie lines (TOP, GOP)
Off-site power for nuclear facilities. (TOP, TO, BA, RC, DP, GO, GOP)
Coordination (TOP, TO, BA, RC, DP, GO, GOP)
Situational Awareness
The Situational Awareness function includes activities, actions and conditions established by
policy, directive or standard operating procedure necessary to assess the current condition of
the BES and anticipate effects of planned and unplanned changes to conditions. Aspects of the
Situation Awareness function include:
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Guidelines and Technical Basis
Inter-Entity Coordination
The Inter-Entity coordination and communication function includes activities, actions, and
conditions established by policy, directive, or standard operating procedure necessary for the
coordination and communication between Responsible Entities to ensure the reliability and
operability of the BES. Aspects of the Inter-Entity Coordination and Communication function
include:
Scheduled interchange (BA,TOP,GOP,RC)
Facility operational data and status (TO, TOP, GO, GOP, RC, BA)
Operational directives (TOP, RC, BA)
Requirement R1:
Requirement R1 implements the methodology for the categorization of BES Cyber Systems
according to their impact on the BES. Using the traditional risk assessment equation, it reduces
the measure of the risk to an impact (consequence) assessment, assuming the vulnerability
index of 1 (the Systems are assumed to be vulnerable) and a probability of threat of 1 (100
percent). The criteria in Attachment 1 provide a measure of the impact of the BES assets
supported by these BES Cyber Systems.
Responsible Entities are required to identify and categorize those BES Cyber Systems that have
high and medium impact. BES Cyber Systems for BES assets not specified in Attachment 1,
Criteria 1.1 – 1.4 and Criteria 2.1 – 2.11 default to low impact.
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Guidelines and Technical Basis
Attachment 1
Overall Application
In the application of the criteria in Attachment 1, Responsible Entities should note that the
approach used is based on the impact of the BES Cyber System as measured by the bright-line
criteria defined in Attachment 1.
When the drafting team uses the term “Facilities”, there is some latitude to Responsible
Entities to determine included Facilities. The term Facility is defined in the NERC Glossary of
Terms as “A set of electrical equipment that operates as a single Bulk Electric System
Element (e.g., a line, a generator, a shunt compensator, transformer, etc.).” In most cases,
the criteria refer to a group of Facilities in a given location that supports the reliable
operation of the BES. For example, for Transmission assets, the substation may be
designated as the group of Facilities. However, in a substation that includes equipment that
supports BES operations along with equipment that only supports Distribution operations,
the Responsible Entity may be better served to consider only the group of Facilities that
supports BES operation. In that case, the Responsible Entity may designate the group of
Facilities by location, with qualifications on the group of Facilities that supports reliable
operation of the BES, as the Facilities that are subject to the criteria for categorization of
BES Cyber Systems. Generation Facilities are separately discussed in the Generation section
below. In CIP-002-5.1a, these groups of Facilities, systems, and equipment are sometimes
designated as BES assets. For example, an identified BES asset may be a named substation,
generating plant, or Control Center. Responsible Entities have flexibility in how they group
Facilities, systems, and equipment at a location.
In certain cases, a BES Cyber System may be categorized by meeting multiple criteria. In
such cases, the Responsible Entity may choose to document all criteria that result in the
categorization. This will avoid inadvertent miscategorization when it no longer meets one
of the criteria, but still meets another.
It is recommended that each BES Cyber System should be listed by only one Responsible
Entity. Where there is joint ownership, it is advisable that the owning Responsible Entities
should formally agree on the designated Responsible Entity responsible for compliance with
the standards.
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Guidelines and Technical Basis
The criteria in Attachment 1’s medium impact category that generally apply to Generation Owner
and Operator (GO/GOP) Registered Entities are criteria 2.1, 2.3, 2.6, 2.9, and 2.11. Criterion 2.13
for BA Control Centers is also included here.
Criterion 2.1 designates as medium impact those BES Cyber Systems that impact generation
with a net Real Power capability exceeding 1500 MW. The 1500 MW criterion is sourced
partly from the Contingency Reserve requirements in NERC standard BAL-002, whose
purpose is “to ensure the Balancing Authority is able to utilize its Contingency Reserve to
balance resources and demand and return Interconnection frequency within defined limits
following a Reportable Disturbance.” In particular, it requires that “as a minimum, the
Balancing Authority or Reserve Sharing Group shall carry at least enough Contingency
Reserve to cover the most severe single contingency.” The drafting team used 1500 MW as
a number derived from the most significant Contingency Reserves operated in various Bas
in all regions.
In the use of net Real Power capability, the drafting team sought to use a value that could be
verified through existing requirements as proposed by NERC standard MOD-024 and current
development efforts in that area.
By using 1500 MW as a bright-line, the intent of the drafting team was to ensure that BES
Cyber Systems with common mode vulnerabilities that could result in the loss of 1500 MW
or more of generation at a single plant for a unit or group of units are adequately protected.
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The drafting team also used additional time and value parameters to ensure the bright-lines
and the values used to measure against them were relatively stable over the review period.
Hence, where multiple values of net Real Power capability could be used for the Facilities’
qualification against these bright-lines, the highest value was used.
In Criterion 2.3, the drafting team sought to ensure that BES Cyber Systems for those
generation Facilities that have been designated by the Planning Coordinator or
Transmission Planner as necessary to avoid BES Adverse Reliability Impacts in the planning
horizon of one year or more are categorized as medium impact. In specifying a planning
horizon of one year or more, the intent is to ensure that those are units that are identified
as a result of a “long term” reliability planning, i.e that the plans are spanning an operating
period of at least 12 months: it does not mean that the operating day for the unit is
necessarily beyond one year, but that the period that is being planned for is more than 1
year: it is specifically intended to avoid designating generation that is required to be run to
remediate short term emergency reliability issues. These Facilities may be designated as
“Reliability Must Run,” and this designation is distinct from those generation Facilities
designated as “must run” for market stabilization purposes. Because the use of the term
“must run” creates some confusion in many areas, the drafting team chose to avoid using
this term and instead drafted the requirement in more generic reliability language. In
particular, the focus on preventing an Adverse Reliability Impact dictates that these units
are designated as must run for reliability purposes beyond the local area. Those units
designated as must run for voltage support in the local area would not generally be given
this designation. In cases where there is no designated Planning Coordinator, the
Transmission Planner is included as the Registered Entity that performs this designation.
If it is determined through System studies that a unit must run in order to preserve the
reliability of the BES, such as due to a Category C3 contingency as defined in TPL-003, then
BES Cyber Systems for that unit are categorized as medium impact.
The TPL standards require that, where the studies and plans indicate additional actions, that
these studies and plans be communicated by the Planning Coordinator or Transmission
Planner in writing to the Regional Entity/RRO. Actions necessary for the implementation of
these plans by affected parties (generation owners/operators and Reliability Coordinators
or other necessary party) are usually formalized in the form of an agreement and/or
contract.
Criterion 2.6 includes BES Cyber Systems for those Generation Facilities that have been
identified as critical to the derivation of IROLs and their associated contingencies, as
specified by FAC-014-2, Establish and Communicate System Operating Limits, R5.1.1 and
R5.1.3.
IROLs may be based on dynamic System phenomena such as instability or voltage collapse.
Derivation of these IROLs and their associated contingencies often considers the effect of
generation inertia and AVR response.
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Criterion 2.9 categorizes BES Cyber Systems for Special Protection Systems and Remedial
Action Schemes as medium impact. Special Protection Systems and Remedial Action
Schemes may be implemented to prevent disturbances that would result in exceeding IROLs
if they do not provide the function required at the time it is required or if it operates
outside of the parameters it was designed for. Generation Owners and Generator Operators
which own BES Cyber Systems for such Systems and schemes designate them as medium
impact.
Criterion 2.11 categorizes as medium impact BES Cyber Systems used by and at Control
Centers that perform the functional obligations of the Generator Operator for an aggregate
generation of 1500 MW or higher in a single interconnection, and that have not already
been included in Part 1.
Criterion 2.13 categorizes as medium impact those BA Control Centers that “control” 1500
MW of generation or more in a single interconnection and that have not already been
included in Part 1. The 1500 MW threshold is consistent with the impact level and rationale
specified for Criterion 2.1.
Transmission
The SDT uses the phrases “Transmission Facilities at a single station or substation” and
“Transmission stations or substations” to recognize the existence of both stations and
substations. Many entities in industry consider a substation to be a location with physical
borders (i.e. fence, wall, etc.) that contains at least an autotransformer. Locations also exist
that do not contain autotransformers, and many entities in industry refer to those locations as
stations (or switchyards). Therefore, the SDT chose to use both “station” and “substation” to
refer to the locations where groups of Transmission Facilities exist.
Criteria 2.2, 2.4 through 2.10, and 2.12 in Attachment 1 are the criteria that are applicable to
Transmission Owners and Operators. In many of the criteria, the impact threshold is defined
as the capability of the failure or compromise of a System to result in exceeding one or more
Interconnection Reliability Operating Limits (IROLs). Criterion 2.2 includes BES Cyber Systems
for those Facilities in Transmission Systems that provide reactive resources to enhance and
preserve the reliability of the BES. The nameplate value is used here because there is no
NERC requirement to verify actual capability of these Facilities. The value of 1000 MVARs
used in this criterion is a value deemed reasonable for the purpose of determining criticality.
Criterion 2.4 includes BES Cyber Systems for any Transmission Facility at a substation
operated at 500 kV or higher. While the drafting team felt that Facilities operated at 500 kV
or higher did not require any further qualification for their role as components of the
backbone on the Interconnected BES, Facilities in the lower EHV range should have additional
qualifying criteria for inclusion in the medium impact category.
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It must be noted that if the collector bus for a generation plant (i.e. the plant is smaller in
aggregate than the threshold set for generation in Criterion 2.1) is operated at 500kV, the
collector bus should be considered a Generation Interconnection Facility, and not a
Transmission Facility, according to the “Final Report from the Ad Hoc Group for Generation
Requirements at the Transmission Interface.” This collector bus would not be a facility for a
medium impact BES Cyber System because it does not significantly affect the 500kV
Transmission grid; it only affects a plant which is below the generation threshold.
Criterion 2.5 includes BES Cyber Systems for facilities at the lower end of BES Transmission
with qualifications for inclusion if they are deemed highly likely to have significant impact on
the BES. While the criterion has been specified as part of the rationale for requiring
protection for significant impact on the BES, the drafting team included, in this criterion,
additional qualifications that would ensure the required level of impact to the BES. The
drafting team:
Excluded radial facilities that would only provide support for single generation
facilities.
The total aggregated weighted value of 3,000 was derived from weighted values related to
three connected 345 kV lines and five connected 230 kV lines at a transmission station or
substation. The total aggregated weighted value is used to account for the true impact to the
BES, irrespective of line kV rating and mix of multiple kV rated lines.
In the terms of applicable lines and connecting “other Transmission stations or substations”
determinations, the following should be considered:
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Guidelines and Technical Basis
connections to other stations. The use of common BES Cyber Systems may negate
any rationale for any consideration otherwise. In the case of autotransformers that
are geographically dispersed from a station location, the calculation would take into
account the connections in and out of each station or substation location.
The Transmission Facilities at the station or substation must meet both qualifications to be
considered as qualified under criterion 2.5.
Criterion 2.6 include BES Cyber Systems for those Transmission Facilities that have been
identified as critical to the derivation of IROLs and their associated contingencies, as specified
by FAC-014-2, Establish and Communicate System Operating Limits, R5.1.1 and R5.1.3.
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Guidelines and Technical Basis
Criterion 2.7 is sourced from the NUC-001 NERC standard, Requirement R9.2.2, for the
support of Nuclear Facilities. NUC-001 ensures that reliability of NPIR’s are ensured through
adequate coordination between the Nuclear Generator Owner/Operator and its
Transmission provider “for the purpose of ensuring nuclear plant safe operation and
shutdown.” In particular, there are specific requirements to coordinate physical and cyber
security protection of these interfaces.
Criterion 2.8 designates as medium impact those BES Cyber Systems that impact Transmission
Facilities necessary to directly support generation that meet the criteria in Criteria 2.1
(generation Facilities with output greater than 1500 MW) and 2.3 (generation Facilities
generally designated as “must run” for wide area reliability in the planning horizon). The
Responsible Entity can request a formal statement from the Generation owner as to the
qualification of generation Facilities connected to their Transmission systems.
Criterion 2.9 designates as medium impact those BES Cyber Systems for those Special
Protection Systems (SPS), Remedial Action Schemes (RAS), or automated switching Systems
installed to ensure BES operation within IROLs. The degradation, compromise or
unavailability of these BES Cyber Systems would result in exceeding IROLs if they fail to
operate as designed. By the definition of IROL, the loss or compromise of any of these have
Wide Area impacts.
Criterion 2.10 designates as medium impact those BES Cyber Systems for Systems or
Elements that perform automatic Load shedding, without human operator initiation, of 300
MW or more. The SDT spent considerable time discussing the wording of Criterion 2.10, and
chose the term “Each” to represent that the criterion applied to a discrete System or Facility.
In the drafting of this criterion, the drafting team sought to include only those Systems that
did not require human operator initiation, and targeted in particular those underfrequency
load shedding (UFLS) Facilities and systems and undervoltage load shedding (UVLS) systems
and Elements that would be subject to a regional Load shedding requirement to prevent
Adverse Reliability Impact. These include automated UFLS systems or UVLS systems that are
capable of Load shedding 300 MW or more. It should be noted that those qualifying systems
which require a human operator to arm the system, but once armed, trigger automatically,
are still to be considered as not requiring human operator initiation and should be designated
as medium impact. The 300 MW threshold has been defined as the aggregate of the highest
MW Load value, as defined by the applicable regional Load Shedding standards, for the
preceding 12 months to account for seasonal fluctuations.
This particular threshold (300 MW) was provided in CIP, Version 1. The SDT believes that the
threshold should be lower than the 1500MW generation requirement since it is specifically
addressing UVLS and UFLS, which are last ditch efforts to save the Bulk Electric System and
hence requires a lower threshold. A review of UFLS tolerances defined within regional
reliability standards for UFLS program requirements to date indicates that the historical value
of 300 MW represents an adequate and reasonable threshold value for allowable UFLS
operational tolerances.
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In ERCOT, the Load acting as a Resource (“LaaR”) Demand Response Program is not part of
the regional load shedding program, but an ancillary services market. In general, similar
demand response programs that are not part of the NERC or regional reliability Load shedding
programs, but are offered as components of an ancillary services market do not qualify under
this criterion.
The language used in section 4 for UVLS and UFLS and in criterion 2.10 of Attachment 1 is
designed to be consistent with requirements set in the PRC standards for UFLS and UVLS.
Criterion 2.12 categorizes as medium impact those BES Cyber Systems used by and at Control
Centers and associated data centers performing the functional obligations of a Transmission
Operator and that have not already been categorized as high impact.
Criterion 2.13 categorizes as Medium Impact those BA Control Centers that “control” 1500
MW of generation or more in a single Interconnection. The 1500 MW threshold is consistent
with the impact level and rationale specified for Criterion 2.1.
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Weighing the risks to overall BES reliability, the drafting team determined that this re-
categorization represents the option that would be the least detrimental to restoration
function and, thus, overall BES reliability. Removing Blackstart Resources and Cranking Paths
from medium impact promotes overall reliability, as the likely alternative is fewer Blackstart
Resources supporting timely restoration when needed.
BES Cyber Systems for generation resources that have been designated as Blackstart
Resources in the Transmission Operator’s restoration plan default to low impact. NERC
Standard EOP-005-2 requires the Transmission Operator to have a Restoration Plan and to
list its Blackstart Resources in its plan, as well as requirements to test these Resources. This
criterion designates only those generation Blackstart Resources that have been designated
as such in the Transmission Operator’s restoration plan. The glossary term Blackstart
Capability Plan has been retired.
Regarding concerns of communication to BES Asset Owners and Operators of their role in the
Restoration Plan, Transmission Operators are required in NERC Standard EOP-005-2 to
“provide the entities identified in its approved restoration plan with a description of any
changes to their roles and specific tasks prior to the implementation date of the plan.”
BES Cyber Systems for Facilities and Elements comprising the Cranking Paths and meeting the
initial switching requirements from the Blackstart Resource to the first Interconnection point
of the generation unit(s) to be started, as identified in the Transmission Operator’s
restoration plan, default to the category of low impact: however, these systems are explicitly
called out to ensure consideration for inclusion in the scope of the version 5 CIP standards.
This requirement for inclusion in the scope is sourced from requirements in NERC standard
EOP-005-2, which requires the Transmission Operator to include in its Restoration Plan the
Cranking Paths and initial switching requirements from the Blackstart Resource and the
unit(s) to be started.
Distribution Providers may note that they may have BES Cyber Systems that must be scoped
in if they have Elements listed in the Transmission Operator’s Restoration Plan that are
components of the Cranking Path.
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Rationale:
During development of this standard, text boxes were embedded within the standard to explain
the rationale for various parts of the standard. Upon BOT approval, the text from the rationale
text boxes was moved to this section.
Version History
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Appendix 1
Appendix 1
CIP-002-5.1, Requirement R1
R1. Each Responsible Entity shall implement a process that considers each of the following
assets for purposes of parts 1.1 through 1.3:
i. Control Centers and backup Control Centers;
ii. Transmission stations and substations;
iii. Generation resources;
iv. Systems and facilities critical to system restoration, including Blackstart Resources
and Cranking Paths and initial switching requirements;
v. Special Protection Systems that support the reliable operation of the Bulk Electric
System; and
vi. For Distribution Providers, Protection Systems specified in Applicability section
4.2.1 above.
1.1. Identify each of the high impact BES Cyber Systems according to Attachment 1, Section
1, if any, at each asset;
1.2. Identify each of the medium impact BES Cyber Systems according to Attachment 1,
Section 2, if any, at each asset; and
1.3. Identify each asset that contains a low impact BES Cyber System according to
Attachment 1, Section 3, if any (a discrete list of low impact BES Cyber Systems is not
required).
Attachment 1, Criterion 2.1
2. Medium Impact Rating (M)
Each BES Cyber System, not included in Section 1 above, associated with any of the
following:
2.1. Commissioned generation, by each group of generating units at a single plant location,
with an aggregate highest rated net Real Power capability of the preceding 12 calendar
months equal to or exceeding 1500 MW in a single Interconnection. For each group of
generating units, the only BES Cyber Systems that meet this criterion are those shared
BES Cyber Systems that could, within 15 minutes, adversely impact the reliable
operation of any combination of units that in aggregate equal or exceed 1500 MW in a
single Interconnection.
Appendix 1
Questions
Energy Sector Security Consortium, Inc. (EnergySec) submitted a Request for Interpretation
(RFI) seeking clarification of Criterion 2.1 of Attachment 1 in Reliability Standard CIP-002-5.1
regarding the use of the phrase “shared BES Cyber Systems.”
The Interpretation Drafting Team identified the following questions in the RFI:
1. Whether the phrase “shared BES Cyber Systems” means that the evaluation for Criterion
2.1 shall be performed individually for each discrete BES Cyber System at a single plant
location, or collectively for groups of BES Cyber Systems?
2. Whether the phrase “shared BES Cyber Systems” refers to discrete BES Cyber Systems
that are shared by multiple units, or groups of BES Cyber Systems that could collectively
impact multiple units?
3. If the phrase applies collectively to groups of BES Cyber Systems, what criteria should be
used to determine which BES Cyber Systems should be grouped for collective
evaluation?
Responses
Question 1: Whether the phrase “shared BES Cyber Systems,” means that the evaluation for
Criterion 2.1 shall be performed individually for each discrete BES Cyber System at a single
plant location, or collectively for groups of BES Cyber Systems?
The evaluation as to whether a BES Cyber System is shared should be performed individually for
each discrete BES Cyber System. In the standard language of CIP-002-5.1, there is no reference
to or obligation to group BES Cyber Systems. Requirement R1, part 1.2 states “Identify each of
the medium impact BES Cyber Systems according to Attachment 1, Section 2…” Further, the
preamble of Section 2 of CIP-002-5.1 Attachment 1 states “Each BES Cyber System…associated
with any of the following [criteria].” (emphasis added)
Additionally, the Background section of CIP-002-5.1 states that “[i]t is left up to the Responsible
Entity to determine the level of granularity at which to identify a BES Cyber System within the
qualifications in the definition of BES Cyber System.” The Background section also provides:
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Appendix 1
Question 2: Whether the phrase “shared BES Cyber Systems” refers to discrete BES Cyber
Systems that are shared by multiple units, or groups of BES Cyber Systems that could
collectively impact multiple units?
The phrase “shared BES Cyber Systems” refers to discrete BES Cyber Systems that are shared by
multiple generation units.
The use of the term “shared” is also clarified in the NERC Frequently Asked Questions (FAQ)
document issued by NERC Compliance to support implementation of the CIP Reliability
Standards. FAQ #49 provides:
Shared BES Cyber Systems are those that are associated with any combination of units
in a single Interconnection, as referenced in CIP-002-5.1, Attachment 1, impact rating
criteria 2.1 and 2.2. For criterion 2.1 “BES Cyber Systems that could, within 15 minutes,
adversely impact the reliable operation of any combination of units that in aggregate
equal or exceed 1500 MW in a single Interconnection.” For criterion 2.2: “BES Cyber
Systems that could, within 15 minutes, adversely impact the reliable operation of any
combination of resources that in aggregate equal or exceed 1000 MVAR. Also refer to
the Lesson Learned for CIP-002-5.1 Requirement R1: Impact Rating of Generation
Resource Shared BES Cyber Systems for further information and examples.
Question 3: If the phrase applies collectively to groups of BES Cyber Systems, what criteria
should be used to determine which BES Cyber Systems should be grouped for collective
evaluation?
The phrase applies to each discrete BES Cyber System.
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