Virtualization in the CIP Environment Drives Discussion of Applicable Systems Classifications

Here's a draft of a Whitepaper I intend to submit to NERC.

Alt Title:

More Problems With EACMS

Summary:

One of the topics entwined in the NEC CIP virtualization discussion is the risk posed by the virtual management consoles. This is related to consolidated interfaces and automation where management console access can change or delete entire infrastructures including virtual servers, networks, and storage. A short-hand phrase has been coined calling this the “Fewer, Bigger Buttons” problem.

Because this is a valid concern that is not really addressed at all in NERC CIP, the scope of discussion quickly grew to address similar Centralized Management Systems (CMS) in the physical arena as well, and from there to all kinds of systems which pose, or appear to pose similar risks.

Statement of the Issues:

The 2016-02 SDT has been discussing several options publicly. One option is to classify CMS (a heretofore undefined term in NERC CIP, and not an industry standard definition in Cyber Security either) as applicable systems and apply specific security requirements to them.

Another option the SDT has discussed is including CMS into the existing EACMS definition. This is more or less by default the approach taken to date with all of those legacy enterprise automation tools. Obviously, this capability and risk has existed, largely unacknowledged in CIP standards, for a long time without being confined to virtualized environments. HP Openview, IBM Tivoli, Solarwinds Orion, and CiscoWorks (to name just a few enterprise automation tools) have had the ability to affect the entire enterprise all at once for literally decades now.

Anti-malware and software patching systems likewise. If a system in my network operates via a system account with administrative privileges that allow it to modify the configuration of a BCS, isn't that tool both a target and a potential attack vector? And if such a system inside my network that performs this function is an EACMS, then isn’t Microsoft’s Software Update Services site, and Ubuntu’s Linux Repository, or Symantec or McAfee’s antivirus signature update sites on the Internet as much an EACMS as any SCCM or Anti-virus server inside my network?

However, this perpetuates and exacerbates an issue where EACMS has become a "catch-all" category of CIP-related Cyber Assets with one-size-fits-all requirements regardless of the degree of risk or technical constraints posed by the particular system.

An example is the Intermediate System. In order to make the IS subject to CIP requirements it has to be categorized somehow as a type of applicable system. To function as an intermediate in practical terms (and by definition per the NERC Glossary) it has to be outside the ESP. Apparently the IS has therefore been categorized as an EACMS simply because that is the only category currently available that allows for applicable systems to be subject to CIP requirements outside the ESP.

Thus, the otherwise-unconnected phrase “This includes Intermediate Systems” was tacked onto the end of the EACMS definition. It is notable that no other examples had previously been given.

The Definition of Intermediate Systems:

“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”

Here we see a presumably audit-able CIP requirement set in the definition of Intermediate System rather than in a table of requirements or in a security objective. We see a cyber security function (Authentication and Authorization) defined as a specific type of applicable device, and we see the security benefit of such a function truncated to apply only to users who interactively access Cyber Assets inside the ESP from outside the ESP rather than applying the benefit of robust authentication, authorization and accounting to all remote access.

Another example of the problem with the one-size-fits-all approach to compliance requirements for EACMS is what is known as the “hall of mirrors” effect. Specifically, there may be some types of Ecyber Security Systems that should be required to be protected behind a firewall. However, that requirement can’t exist for all EACMS without defining a new category because a firewall is itself an EACMS. Without defining a new category, the result would be every EACMS needing to be inside an ESP and protected by another EACMS which creates a recursive "hall of mirrors" effect without end.

In addition to the catch-all and recursive problems I've just noted, there is also a missing component: Risk-based assessment and mitigation. For example, a system that only monitors and logs access (such as monitoring systems like Splunk, Tripwire, etc) does not pose the same level of risk as a management console for a large virtualized Control Center infrastructure. In addition, the technical controls to mitigate the risk may differ. A SIEM system presents a risk of leaking BES Cyber System Information; an electronic access control (AAA) system presents a risk of unauthorized access to or modification of a BES Cyber System’s operational parameters; and a Centralized Management Console (physical or virtual) presents an infrastructure reliability risk.

Risk-based assessments and mitigation would help with this. It would allow for acknowledging that there are a number of systems that both monitor and provide part of the solution of controlling access, but which do not actually control traffic at the point of entry. These devices or systems may or may not benefit from being inside a protected boundary, or they may form part of the strategy that protects BES Cyber Assets. The technical means of implementing some multi-part systems may require that components be outside or that they span the ESP.

All of this appears to be an unfortunate artifact of the single-level security mindset inherent to the ESP approach (hardened perimeter defense) and the “All-In” nature of CIP Applicable Systems. Part of this problem (creeping scope of applicability to increasingly peripheral systems) stems from using the ESP to define scope of applicability, rather than using risk to BES Cyber Systems and security objectives to define the scope of necessary controls. FERC does not allow a Registered Entity to assess and accept their own risks due to the interconnected nature of risk to the BES. At the same time, NERC and the Regions have zero incentive to accept risks on behalf of Entities. NERC and the Regions bear none of the cost of mitigation, and would receive the lion's share of criticism in the case of a failure of reliability or security breach. It is very difficult to create standards that are effective, comprehensible, and inclusive of different technical capabilities, based upon the existing definition of EACMS or even new definitions structured with the same ESP-as-hardened-perimeter mindset. ESP is easy to visualize. Drawing a “red dotted line” around assets needing protection is convenient. It’s simply not sufficient. In contrast, a modern defense-in-depth, systems- rather than device-based approach doesn’t require torturing definitions.

With these examples in mind, the issues caused by having EACMS as a “catch all” category are obvious. Some applicable systems were defined into existence for compliance purposes and these standards are incompatible with broader standardized cyber security best practices, and with one-size-fits-all requirements applied to the whole artificial group.

Recommendations:

So what do we do about it?

1. The audit process needs to envision an approach more concerned with meeting an objective than a performance requirement. Then it doesn’t matter where something resides, as long as the applied combination of protections achieves the objective. It doesn’t matter much what is providing the control, as long as the assets needing protection receive the control. For example, the implied security objective of CIP 5 is not to “have inbound and outbound rules”. That is a limited method of achieving the real objective, which is to protect the BCS from unauthorized and potentially malicious traffic. If you have a better method, you should be allowed to use it.

2. It might be necessary to break up the EACMS category of applicable systems into discrete functions (bullet points below) so that the appropriate security objective and requirements for each can be derived and applied whether the systems in question are physical or virtual.

• SIEM - Security Incident & Event Monitoring systems.

This would subtract the “M” for “Monitoring” from EACMS. These are systems that strictly monitor and collect information about the ESP and BES Cyber System electronic communications or status but do not control access. A great deal of literature, discussion, guidance, and best practices are published across a broad range of industries as to how to securely implement SIEM. The risk presented by compromise of these systems revolves around the information (such as configurations and event logs) they contain. The crux of the concept here is that the protections already defined for BES Cyber Systems Information (BCSI) are adequate and effective at providing protection for this information, and it is the information that needs protecting, not necessarily the SIEM system.

A rather large issue with EACMS is CIP-004 and its applicability of most personnel-oriented controls (training, background checks, etc.) to anyone with potential access to an EACMS. This kills sharing any service whatsoever (AAA, SIEM, etc.) because anyone with any form of “access” to an EACMS gets sucked into CIP-004. Have an account on a EACMS AAA server but NO access to any BCS? Too bad, you still must have a CIP background check and be trained on the CIP program (beyond your ‘need to know’). It’s a symptom of the “all-in” issue.

Splitting these monitoring systems out and adjusting the requirements would may allow entities to more easily use outsourced managed security service providers or global/enterprise-wide SIEM systems and correlate event information in their CIP operational environments with those in their non-CIP environments to provide increased security and reliability benefits. The concern is that under current standards the CIP program and device-level CIP audits might be deemed to encompass Cyber Assets which do not actually affect the reliable operation of the BES in the wider enterprise network or at the service provider and could therefore dilute attention from BES Cyber Security functions in favor of paperwork exercises.

• EACS - Electronic Access Control System. The fundamental defining characteristic of an Electronic Access Control system is that it performs authorization of traffic or users. This is the gatekeeper function- the classic Authentication and Authorization functions of standard AAA.

In many cases these systems do not perform any active filtering of the traffic passing through any particular interface. The primary duty of EACS is to authenticate and authorize. Additional components of electronic access security strategies are accounting (logging) systems and gateways which actually pass or drop traffic. In comparison to the SIEM discussion above, EACS & EAG move beyond the risk of unauthorized access to meta-information about an environment to unauthorized access to and modification of operational parameters of the actual BES Cyber Systems.

In contrast, theoretically an application level IPS could send a control signal from anywhere in the enterprise to anywhere in the enterprise telling a specific host not to respond to a given type of packet, with a certain payload, from a particular address- and it could do this dynamically based upon heuristics rather than signatures, but this outstanding security solution would not be a compliant solution under our current regime.

Or a network level intrusion protection system combined with dynamic firewall rules may send a control message to a firewall instructing it to dynamically change an Access Control List (ACL) in response to traffic patterns indicating a threat. The IPS does not itself filter traffic in this scenario, but it is involved in controlling access. An Active Directory server may enforce a lock-out on a user account after hours or subsequent to a number of incorrect password attempts. It is involved in controlling access (authentication and authorization), but it is not blocking traffic at layer 3 and from the current NERC CIP ESP perspective is therefore irrelevant in boundary protection. All boundary protection requires access controls, but not all access control is boundary protection.

A metaphor for Access Control Systems that do not reside in or on an ESP/ESZ is: a pair of military units with interlocking fields of fire supporting each other against frontal assaults and flanking movements. Defense relies upon being positioned to assist one another, not on “being inside a fence”. Electronic Access Control Systems (AAA) can work to protect Cyber Assets inside the ESZ from anywhere.

• EAG - Electronic Access Gateway. The fundamental defining characteristics of an EAG are that it hosts the EAP and performs the active function of filtering or forwarding traffic at the demarcation point (boundary protection). Primarily it is firewalls and routers that perform gateway functions at the layer 3 ESP boundary demarcation point. Virtual firewalls and virtual routers inside a hypervisor perform the same function in the same manner. However, hypervisors themselves may not be EAGs if they are not configured with a virtual firewall or virtual router function to provide a gateway function.

Modern security methods typically employ a defense in depth strategy using distributed AAA (Authentication, Authorization, and Accounting) systems to authenticate and authorize access to the Electronic Security Zone based upon characteristics of the user and traffic, while the EAG subscribes to the AAA service for user permissions and filters (permits or denies) traffic based on the source, destination, and port or protocol. Further, Electronic Access Control strategies often employ multiple devices, each containing a part of the AAA solution, such that compromise of one element of AAA does not result in the entire system failing. Vendor and platform diversity within a defense-in-depth systems-based approach to Access Control are generally an element of securing the entire system from vulnerabilities common to specific classes of devices (e.g. all-Windows or all-Linux environments may have common configuration or malware vulnerabilities). Often the Accounting (logging) function is used to determine (and formulate a strategy to correct) any failures in Authentication and Authorization. 

Although some EAG devices are also capable of performing various levels of functions to authenticate and authorize traffic, many are not capable of complete AAA solutions in themselves and therefore differ enough from EACS to warrant different technical control measures. Requirements that acknowledge the difference and allow for handling them differently will prevent any "hall of mirrors" effects as described above only. 

For conceptual discussion purposes EAG acts somewhat like the legacy ESP as a logical demarcation point for conceptual discussions to delineate PCA and BCS from non-CIP-Applicable Cyber Assets. It may even be useful to replace ESP completely using ESZ with EAG for demarcation points.

• CMS - Centralized Management System. System using an elevated privilege account either on behalf of an interactive user or in an automated fashion, allowing mass modification of BES Cyber Systems.

As discussed, these systems are the ones driving the SDT's apparent thought process. The risk posed by these systems is not just unauthorized access to information or BES Cyber Systems, but the ability to modify or destroy the infrastructure the BCS rely upon, or the BCS themselves. These will have unique requirements over and above the others. It would obviously not be beneficial to simply create a reclassification and documentation exercise for entities who would not see sufficient benefit.

Proposed definitions:

AAA: Authentication, Authorization and Accounting systems are Cyber Systems that control ‘Gatekeeper’ functions (electronic access methods and permissions, e.g. authentication of users or control messages that alter dynamic ACLs) for Cyber Systems.

CMS: Centralized Management Systems are Cyber Systems that perform automated management tasks and mass configuration of BCS whether scheduled or on demand using a dedicated service account credential.

EACMS: Deprecated.

EAG: An Electronic Access Gateway is a Cyber Asset that performs active electronic traffic control (filtering and/or forwarding) for ESZ boundary protection based upon the criteria given to it.

EAP: An Electronic Access Point is the logical interface on an EAG where traffic filtering operations take place. 

ESZ: An Electronic Security Zone is the logical container providing separation or isolation from threats or attack vectors to grouped Cyber Assets, said Cyber Assets being characterized by similar operational criticality, or sensitivity to compromised data confidentiality and integrity, as well as needing similar access controls, audit logging and/or monitoring requirements.

SIEM: Security Incident & Event Monitoring is a Cyber System that performs electronic monitoring of Electronic Security Zone(s) or Cyber Systems. 

The problem with EACMS

The NERC CIP Glossary is foundational to the (let us not forget "mandatory and enforceable") CIP Standards

One of the terms defined there is Electronic Access Control or Monitoring System (EACMS):

"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."

Disregard the last sentence for a moment. There are a few examples of throw-away statements like this added in NERC CIP for convenience, or exceptions where no one could think of wording that would be universally applicable.

Focus on the meat of the definition: it's an access control and access monitoring system. Outside of NERC CIP Standards, this is generally known as AAA: Authentication, Authorization, and Accounting, which actually captures the steps involved in granting and monitoring access much better than the EACMS definitions. There is also tons of guidance and information on implementing AAA in the broader IT Security realm.

But ignore that for a moment too.

The real problem with NERC CIP Standards and the applicable systems that they list, is that some systems that fall into the EACMS category (plus a number which don't) actually pose a much more significant risk than simple access management. They actually perform configuration management via "service accounts" with elevated privileges.

So for example, an Active Directory system is an EACMS, even though it not only controls access, it also controls configurations. But there is no requirement in NERC CIP to monitor the configuration changes made during a session, only the access to the system. Specifically, the failed and successful login attempts.

SCCM is not specifically an EACMS, even though it has an agent installed on Windows devices, and has an elevated privilege service account with Domain Administrator equivalent permissions. But it doesn't control or monitor access attempts.

There is no requirement to protect these systems any differently than any other user-accessible system, like perhaps a data portal on a web server. There is no requirement to separate user or system access within an ESP based upon roles, or impact levels (another problem with NERC IP is impact level is based upon the facility's physical impact on the Bulk Electric System, not the Cyber System's impact on operations). Once you're in, you're in and there is no requirement and not even any explicit security objective to do more than guard the perimeter. As I've mentioned before, this is the "hard crunchy shell, soft gooey center" model from 20 years ago.

On top of that, there's an exemption to remote access requirements for machine-to-machine communications. A management system located outside the Electronic Security Perimeter isn't even required to have encryption, and has no special requirements above and beyond the simple baseline, change management, and logging requirements applied to any system used to support the BES.

Weird.

GAAP... GASP...

Tom Alrich says that, at the RF CIP workshop Lew Folkerth pointed out that:

"the key to being able to audit non-prescriptive requirements is for the entity to have to demonstrate that the measures they took were effective."

A lesson can be taken here from the principles of GAAP: "Generally Accepted Accounting Practices". 

Paraphrasing GAAP: There is no absolute, perfect accounting during an audit. There are only sliding scales of better and worse practices. You must depart from [the accepted practice] if following it would lead to a material [mistake]. In the departure you must disclose, if practical, the reasons why compliance with the principle would result in a [mistake].

I know that the electric utility industry doesn't like outside influence, and has a severe "not-invented-here" allergy. But we really do need to move toward "Generally Accepted Security Practices" (GASP, to flippantly coin an acronym.)

So the take-away is that an entity should be able to demonstrate either that the novel approach they took is effective via testing (such as penetration testing), OR that it is widely "accepted" as a security best practice. Making every entity extensively, intrusively pen test every single product, software update, and configuration is counterproductive, and outside the core competency of the entity. Vendors and security firms test these things and make recommendations. Other than due diligence in researching a solution and verifying the provenance and integrity of software or firmware to be installed, an entity shouldn't have any particular obligation to "prove" perfect security of a commercial software offering or hardware device, because it's a distraction from the real issue.

The real issue is providing overlapping defenses in depth.

Where does "Resilience" rank in NERC CIP?

The NERC CIP discussion has an oddly blank spot when it comes to the Reliability discussion. Reliability seems to mean "always available with no outage" to most people.

I'll agree, that's a good goal for the Bulk Electric System. It's just not a very achievable goal for every single Cyber Asset in the BES.

In the world of Disaster Preparedness/Disaster Response, IT security, Business Continuity Planning, and the remainder of the Critical Infrastructure sectors, the main conversation is around Resilience, not perfection. 

We know bad guys will win sometimes. We know mistakes will be made sometimes. It's important to be able to recovery quickly with minimal residual damage when these things happen. We have to look at Risk Management in terms of 5 strategies:

• Avoidance
• Transference
• Reduction
• Mitigation
• Acceptance

Avoiding risk is difficult when you're a large, stationary, tempting target. Transference is not practical for Critical Infrastructure- there's nobody outside the system to insure you against damage.

So we try to reduce risk by reducing or eliminating vulnerabilities We can't do anything about reducing threats. Many of our threats are either criminal elements or nation-state actors. these threats are for law enforcement and military force to deter. We're stuck trying to close off attack vectors (vulnerabilities to particular types of threats). We try to reduce the probability of exploit by narrowing the windows of opportunity for threat actors to exploit those vulnerabilities with things like timely updates of security patches, malware signatures, and periodic tests of security mechanisms and logging. The problem is we can do a good job of whack-a-mole and still fail on a zero-day exploit (which is a combination of a threat and a vulnerability) that either didn't exist yesterday, or was unknown to us.

FERC has told Responsible Entities that we're not allowed to accept risk on our own, because our entanglement in the Bulk Electric System means we'd be accepting risk for the whole system, not just ourselves. The Regions who audit us have permission to accept risk on our behalf but no incentive to do so because they bear none of the cost of mitigation for those risks, and would be exposed to criticism and worse if it came to light that a risk deemed "acceptable" had been exploited.

So, mitigation.  It sort of overlaps with risk reduction in common conversation; people often use the term mitigation to mean reducing vulnerabilities. This isn't really precise from a Risk Manager's perspective. That's actually risk reduction. Mitigation is more about controlling the amount of damage that can be done if an exploit is successful.

One way of limiting the damage is having a means to quickly restore vital capabilities. Another way is to have a means of rapidly addressing vulnerabilities once they are exploited. And we can also spread our eggs out into different baskets so any particular attack can only get to some of them. Anything that limits the scope, impact, or duration of damage is a mitigation strategy.

Mitigation plans are the heart of Resilience. When Reliability efforts reach the point of diminishing returns, we need to start talking about contingencies, and that means Resilience. How many times does this concept appear in the NERC CIP standards? Without losing the emphasis on risk reduction, we need to start including resilience strategies in our planning.

Rapidly evolving threats & slow-moving regulatory standards

Over at the Anfield Group Blog, Chris Humphreys posts: 

The DOE’ s Quadrennial Energy Review Report states that:

“The current cybersecurity landscape is characterized by rapidly evolving threats and vulnerabilities juxtaposed against the slower-moving prioritization and deployment of defense measures.” I lump regulatory standards and requirements into the “slower-moving prioritization and deployment of defense measures” as one of the key components to preventing a truly proactive stance on cybersecurity. Additional focus on recovery and resiliency needs to be a foundational element of any cybersecurity program because the idea that an organization can combat against 100% of cyber intrusions is false. What becomes critical is the recovery of the system if/when a successful cyberattack occurs."

I couldn't agree more. We will never eliminate all risk.So it behooves us to have a backup plan- resilient recovery strategies. NERC CIP's specific language around redundancy doesn't dismiss the importance of redundancy, but a lot of NERC CIP compliance folks do. The language says one cannot exclude a Cyber Asset from scope of CIP simply because the system is redundant. Fair enough. Redundancy doesn't protect from software vulnerabilities, malware, or mis-configuration. But too many people seem to think that this means redundancy doesn't matter, and in fact, there doesn't appear to be any requirement to have redundancy for Cyber Assets. 

Something that NERC CIP doesn't do well: make clear that assessing technical controls for high availability at the systems level rather than at the device level can provide a more accurate perspective on real cyber security, and this high availability is achieved through redundancy of underlying infrastructure (perhaps switching and virtual network systems, or hypervisor infrastructure) that has little or nothing to do with BES functions, BES Information etc. Building resiliency in and eliminating reliance upon single devices (or as I like to call them, "single points of failure") is a key part of virtualization's benefit.

The entire mindset behind and promoted by the NERC Glossary and the definition of BES Cyber Asset is to blame for this lack. Add that to the prescriptive requirements, device-centric example measures, and the device-oriented Severity Level tables, and you get a self-reinforcing  echo chamber about how to achieve reliability that makes it difficult to look outside the way it has always been done.

A Tale of Two Viewpoints: Mixed Trust vs Shared Infrastructure

In NERC CIP Standards Drafting efforts, industry chatter, and auditing, there has been quite a bit of talk about “mixed trust”; meaning an environment that has both BES Cyber Systems and Cyber Assets not subject to CIP standards. Non-CIP Cyber Assets may be systems that are under the Responsible Entity’s control, and may even be providing functions related to Grid Operation, but not functions which “if rendered unavailable, degraded, or misused” for 15 minutes will affect the reliability of the Bulk Electric System. For example, corporate business systems are not BES Cyber Assets, even though they are under the control of the same Responsible Entity as the BES Cyber Systems.

Here’s the thing; “mixed trust” is not the right term. Mixed trust would imply that Cyber Assets of different trust levels can access each other in an uncontrolled fashion. Nobody is proposing a relaxation of security controls between CIP and non-CIP assets. What is being proposed is “shared infrastructure”. At some level we all have shared infrastructure- the same building, the same power, the same Internet connection. Shared Infrastructure doesn’t mean “mixed trust”. Shared Infrastructure can have logical controls and isolation involved.

A few days back, I wrote about Streetlight Effect in relation to Lew Folkerth's "Lighthouse" article in the March-April issue of Reliability First's newsletter. In it he talks about “Zones of Authority” in relation to the audit process for NERC compliance. At the end of the article he makes an assertion about Virtualization being a bad idea not because of actual security concerns, but because of the auditor’s inability to look at things outside of the designated Electronic Security Perimeter (compliance concerns) required for BES Cyber Assets. While I respect Lew's experience and appreciate the viewpoint, I disagreed with that approach pretty strenuously.

Tom Alrich has another perspective on the article. He makes a point about security being enhanced if the RE’s entire network were in scope for NERC CIP Compliance audits. I don’t think I can agree with that either (although he does acknowledge that the average compliance specialist would rather repeatedly hit themselves in the head with a hammer than take this approach because of the burden of paperwork involved, so it doesn’t appear to be a serious suggestion.) Such an approach would only be a net gain if compliance evidence production didn’t overwhelm the efforts to secure things in the first place. And if all of the compliance requirements were strictly security requirements and not just designed to make audits easier.

But realistically, bringing security mechanisms that exist outside the ESP (Electronic Security Perimeter) into scope of auditing doesn’t require making the entire corporate network subject to inspection by the Regions. Here's the problem with CIP-005 and ESP. Most NERC CIP standards require you to have a program or process to accomplish X. CIP-005, on the other hand, requires everything peripherally related to BES Cyber Systems to reside inside the ESP. What we have here is the "hard crunchy shell" concept from 20 years ago. It provides “bright line” criteria for audit and categorizing assets as either in-scope or out, because the auditor can require a diagram with the asset shown inside a neatly drawn “dotted red line” (inside joke for NERC CIP compliance specialists), but it doesn’t provide good security on its own.

Some of this difficulty is definitional. A PCA "protected cyber asset" is any cyber asset "associated" with a BES Cyber System and can exist "in or on" an ESP, but this is only made specific in the NERC Glossary.  A BES Cyber Asset must be contained in an ESP (CIP-005). An Intermediate System must reside outside the ESP. An EACMS can be in or out.

Documenting a mechanism that provides a security function doesn’t require that everything else on that network be in scope for auditing. Authentication, Authorization, and Accounting (AAA) may be partly provided by an RSA Token system. That AAA system could reside inside or outside of the security zone where clients of the system exist. The documented controls for CIP AAA could bring that RSA server into scope without touching other, unrelated non-CIP servers on its network segment.

The key to providing good security for BES Cyber Assets doesn’t rely solely upon whether a device is inside a particular perimeter. It depends upon the controls applied to accessing that device. A layered defense of the device includes boundary identification & control, but it doesn’t stop at the outer boundary.

Let's address a couple specific points:

"Lew says (or implies) that auditors are having differences of opinion with entities on the security of mixed-trust switches. It seems these entities have switches that implement both ESP and non-ESP VLANs. When the auditors tell them this isn’t secure, the entities point out that the non-ESP VLANs have just as good security as the ESPs do. So why aren’t they safe?"

Let's examine a scenario with two VLANs, one named "CIP" and one named "non-CIP". The main point really isn't that the security of "non-CIP" is as good as "CIP". The most important thing is that network isolation is maintained between them. The configuration of devices in one VLAN are irrelevant to devices in the other VLAN. If it's just a Layer 2 VLAN, there is no "mixed trust" because the traffic from "non-CIP" doesn't mix with that of "CIP". If it's a Layer 3 switch, and routing takes place between the 2 VLANs, then an EAP must be identified (probably the VLAN's logical or virtual interface) and inbound/outbound access controls applied at that point. If it is a Hypervisor situation, then the same principle applies. vSwitch "non-CIP" doesn't have a traffic path that includes vSwitch "CIP" and the Guests cannot communicate with each other. If you create an EAP between them, then you apply the inbound and outbound access controls at that point.

And lest we forget, L2 VLAN is not the only way to have a shared switch infrastructure. Software Defined Networks and Network Overlays exist on a shared hardware infrastructure, but provide network isolation between the security zones as defined in configuration. This isolation, like that of the VLAN example above, is provided as a baseline function of the device, implemented in the control plane by code base. Access to modify configuration and code base is confined to a management plane interface. Traffic transiting the device doesn't have access to this function, only administrators accessing the device in the management plane do.

"Anything else, such as a VLAN that isn’t an ESP, is completely out of his or her purview; the auditor just has to assume these are completely insecure, and thus shouldn’t be found on the same switch as ESP VLANs."

Auditors aren't forced to assume anything.  The configuration of the switch is in scope, because it provides isolation to the "CIP" VLAN. (It doesn't provide ESP under the current model, because it doesn't provide EAP with in-bound/out-bound ACLS. It simply provides isolation, which is one flaw in CIP-005's prescriptive approach. CIP-005 would benefit from being changed to a security objective of isolating more critical assets and traffic from less critical.)The configuration of devices in the "non-CIP" VLAN are out of scope. If something is out of scope, they are not required to render an opinion on it.

"the auditors can’t look at what isn’t in an ESP, which limits the kinds of evidence an entity can show them. "

Currently, auditors can examine EACMS that may exist outside the ESP. They can examine Intermediate Systems which are required to be outside the ESP. I don't think this is a valid assertion. It's an auditing approach preference with deliberate blinders on.

"most entities, if told they could force CIP auditors to consider security controls they have implemented for non-ESP networks, but only in return for having at least some of the cyber assets on those non-ESP networks fall into scope for CIP, would say “Thanks but no thanks. We’ll leave things as they are.”

Perhaps the entity might choose that. But the issue isn't "security controls implemented for non-ESP networks." It is "security controls that exist outside the ESP, that are implemented to protect CIP Assets". ESP is a fundamentally limited construct, and must be considered fatally flawed when used without other other layered defenses.

From the EnergySec website:

"EnergySec published comments on the Transmission Owners Control Center and Virtualizations white papers the Standards Drafting Team is seeking comments on. Since EnergySec does not formally vote on SDT ballot issues, we are not formally submitting these comments to the SDT. However, we are making them available for our members to use or revise as they see fit. The documents are available in the Members section of the EnergySec Community wiki."

Not only are they not formally submitted, it would appear that almost no one on the SDT or the NERC staff associated with it actually has access to read it. You would think that something like this would be more use to their membership if it were not behind a pay wall.

Virtualization Webinar Today (NERC CIP Standards Drafting)

 

Industry Webinar Project 2016-02 Modifications to CIP Standards Virtualization in the CIP Environment April 18, 2017 | 3:00 – 4:30 p.m. Eastern   Click here for Webinar Registration Dial-in: 1-415-655-0002 | Access code: 731 913 110
Background In addition to the Order No. 822 directives, the Project 2016-02 Modifications to CIP Standards Drafting Team (SDT) is addressing four issues identified by the CIP Version 5 Transition Advisory Group (V5 TAG). These issues are: ·         Cyber Asset and BES Cyber Asset Definitions; ·         Network and Externally Accessible Devices; ·         Transmission Owner (TO) Control Centers Performing Transmission Operator (TOP) Obligations; and ·         Virtualization   Virtualization of Cyber Assets provides advantages for the availability, resiliency, and reliability of applications and functions hosted in such an environment when implemented in a secure manner. The SDT is offering a series of webinars in an effort to provide a resource for technical information related to several concepts relevant to virtualization. During the first webinar, held on March 21, 2017, the SDT discussed logical isolation and Centralized Management Systems (CMSs), in addition to introducing storage virtualization.   Webinar Objectives This second webinar will discuss the Hypervisor with a special focus on template considerations, as well as multi-tenancy and the concepts of underlay hardware and Electronic Security Zones. This webinar will also expound on the introduction to storage virtualization provided in the first webinar, to include discussion of storage area networks and the manner in which underlying virtualization concepts are similar to server virtualization. Finally, this webinar will discuss storage virtualization scaling and data leakage.
For more information or assistance, contact Katherine Street (via email) or at (404) 446-9702 or Mat Bunch (via email) or at (404) 446-9785
3353 Peachtree Road NE Suite 600, North Tower Atlanta, GA 30326 404-446-2560 | www.nerc.com

 

Definitions matter

There is a need to revise CIP language to clarify “programmable” due to differences between the current NERC CIP definition of Cyber Asset, the language in Section 215 of the Energy Policy Act of 2005 that discusses Cyber Assets as Electronic Programmable Devices, and commonly understood security standards and definitions of computers or cyber devices.

There is a perception that the particular wording of “Cyber Asset” is a deliberate, well-thought-out, and legally binding definition. However, there are multiple inconsistencies between NERC CIP Standards, the Energy Policy Act, and FERC Orders which have not been legally challenged and have not prevented progress from being made to security standards. This being so, there is no practical benefit in objecting to modifications based on a presumption of precision in the original wording.

These varying definitions have caused some confusion in categorizing Cyber Assets as in-scope. There may be gains to be achieved by modifying the definition to be more consistent both internally and with cross-sector IT security practices that are more technically in line with the way devices are designed by vendors and intended to be operated. When the parsing of the grammar becomes too circular, the utility of the definition is lost. The main goal of NERC CIP standards MUST be usefulness of the standard.

Some commenters have made the point that NIST does not use the term “Cyber Asset” and recommend using the term “computer”. However “computer” also has connotations of server/workstation to many people and is not inclusive of other information processing devices such as network and security appliances, cyber-physical industrial control system devices, etc. “Cyber Asset” is a workable, comprehensible and inclusive term that provides benefit to the security discussion and therefore should be retained.

Cyber Assets are platforms which can accept variable sets of encoded instructions known as operating systems and software programs. They use these instructions to manipulate data inputs to create outputs in the form of processed data or in the case of Cyber-Physical devices, control signals. This programming is stored in either volatile or non-volatile memory, and may reside in the device or on other devices in the overall Cyber System that provides storage services to the device.

Conversely, dedicated devices which perform a function defined purely by the physical configuration of the device (dip switches, jumper connectors, or EEPROM) and not in a changeable, encoded set of logic-based instructions are not generally considered to be Cyber Assets, but rather microprocessors. The modification of that dedicated function (control plane logic) is not programmable via a human or network-accessible communications interface (management plane) that can be interacted with logically by other Cyber Assets. Re-programming requires physical modifications to the micro-processor device, often by a vendor technician at a factory using tools that change the physical or electrical properties of the device. These devices are not in any practical way “programmable” by the user and the risk of them being re-programmed maliciously or covertly are mitigated by physical access controls.

Additionally, devices which have a stored firmware not accessible unless installed in another device (such as but not limited to internal/external hard drives, flash drives, Ethernet or Wireless NICs cards or USB, Security dongles, serial adapters, etc.) are not Cyber Assets in themselves because they are not capable of being re-programmed or executing code without being installed (permanently or temporarily) in a Cyber Asset. These types of devices are peripheral components of a Cyber Asset or removable media. While these devices may pose a risk of carrying mal-ware, the means of mitigating that risk is separately covered by removable media controls and supply chain requirements.

Electronic Security Perimeter

Over at his blog, Tom Alrich commented to me:

"objectives-based requirements are the only way not to have the situation you discussed (drawing from Lew Folkerth's recent article in RF's Newsletter)- where an entity can be doing great things for cyber security that the auditors can't even consider because they're not in their "zone of authority" (in this case, the ESP). 

Objectives-based requirements would have to be built on top of a framework of concepts that goes beyond just BCS and ESP's, to include all of the entity's computing infrastructure (including "IT" networks)."

I definitely agree that the ESP construct is inherently limiting. For one thing, it is established by arbitrarily drawing a line, identifying where the access point (with controls applied) is, and it only exists at OSI Model Layer 3: routable protocols. Lest we forget, not all security takes place at Layer 3, it's simply the easiest place to measure.

Right now, guidance from NERC and the regions tells us that we cannot use a Layer 2 switch with some ports inside the ESP and some outside. Some would argue you can't use any switch, even a Layer 3 or 4 switch this way. However, there is no requirements language that says this is the rule. It's not a clearly established and absolute security best practice. The reason there can't be any NERC CIP requirements around this is because the ESP is defined strictly at Layer 3, and it was done that way on purpose to exclude Layer 2 connections from needing ACLs (access control lists) and firewalls. Here's the relevant reasoning from CIP-005  Guidelines & Technical Basis: 

"This requirement applies only to communications for which access lists and ‘deny by default’ type requirements can be universally applied, which today are those that employ routable protocols. Direct serial, non-routable connections are not included as there is no perimeter or firewall type security that should be universally mandated across all entities and all serial communication situations. There is no firewall or perimeter capability for an RS232 cable run between two Cyber Assets. Without a clear ‘perimeter type’ security control that can be applied in practically every circumstance, such a requirement would mostly generate technical feasibility exceptions (“TFEs”) rather than increased security."

It's not easy to measure security being applied to layer 2, so we define this type of connectivity out of relevance. Good security would be to apply controls upstream to those devices which can participate, but the device-centric focus of early CIP standards language leads people away from thinking in these terms. Security doesn't have to be "perimeter" based, and generally in a modern layered approach security functions are distributed across multiple devices/systems within your network. They're not all "on the perimeter" so the current NERC CIP standards apply poorly if at all to this strategy. We need some changes to the dominant paradigm. At the same time, we don't need auditors crawling into every ancillary system in our IT department.

Some concepts that add to the discussion:

Accessing a device means the ability to view/modify it's configuration settings. This can be because the device interacts only in the data plane and doesn't have a separate management plane, i.e. a Windows Server. It could be access to a dedicated management port.

Traffic transiting a device means that the packets are forwarded via that device. It doesn't necessarily mean that the user originating the traffic has the ability to view or modify the device in question, in most cases they may not even be aware that the device exists in the traffic stream. Packets crossing a router, switch, or firewall in the data plane would be examples.

Management plane is the logical function which allows a user to interact with the configuration settings of a system. It includes any dedicated management ports, the user interface (terminal emulation of graphical users interface), and the network connectivity to these if accessing remotely (really remote access, which means from anywhere not directly connected, not NERC CIP remote access which only means from outside the ESP).

Control Plane is the logic embedded in the code base of the system. Admins can modify the control plane logic, but usually only by replacing the code base (upgrades, patching, etc.)

Data plane is just packet switching. traffic is generated by users or devices, and sent to a destination IP address. It is switched, routed, forwarded to devices inline along the way. This traffic has no access to the Control Plane or Management Plane on a properly configured network appliance (including hypervisors).

Determining Metrics & Requirements

On Thursday, I wrote a bit about defining BES Cyber Assets, in response to some older discussion on the WICF Forum that is still an undecided topic of discussion today.

It's funny how often the definition of BES Cyber Asset has to be discussed. Tom touches on it again here in talking about the difficulty of an auditor determining whether something is a BCA based upon legal semantics. The BES CA definition is:

"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 equipment shall not be  considered when determining adverse impact. Each BES Cyber Asset is included in one or more BES Cyber Systems."

In NERC CIP Standards, definitions are often contrary to plain language or commonly-understood terminology, and all-too-often include definition by exclusion, even when it tortures reading comprehension. In the definition above, they are intending to close a loophole that one might exploit to get out of compliance scope. And to the point that an identically-configured system might be just as vulnerable to a flaw or cyber attack, it's a valid point. But there are many scenarios where redundancy alone makes the idea of a functional impact into a very remote possibility.

The same article from Tom crosses over to touch upon the Streetlight Effect I wrote about here and here, and is particularly apt with the tagline I ended the second article with: "When your auditor insists upon a simple and clean way to measure compliance at the device level, they may be doing us all a disservice."

It boils down to a common management problem. I can't manage what I can't measure, because to determine the effectiveness of processes I must determine whether they change an outcome and whether that change is positive or negative. So determining what to measure and how it is related to a specific process is necessary, but the problem is that this is not always easy. Some measurements are meaningless. They either don't relate to the process, or the relate to the wrong (or misunderstood) process and therefore indicate results unrelated to the change I'm trying to make. If I don't choose the right test points and interpret the test results correctly, I am not gaining anything other than a thin cover story for why it's not my fault when things go drastically wrong. We have lots of people measuring lots of things and producing tons of documents to prove that they're testing them.

But are we looking at the right things or just the easy ones?

5 Things About the Electric Industry

Amy Thomas, Government Relations Director, American Public Power Association blogged "Five Things You May Not Know about Cybersecurity in Electricity" back on February 24th.

The public may not know these things about the Electric Utility Industry, but insiders do and it's not ALL puppies and sunshine:

1. The electric utility sector is the only critical infrastructure sector (besides nuclear power plants, which are a part of the overall sector) that has mandatory and enforceable standards in place for cybersecurity.

{emphasis in original} 

That's certainly interesting. It sort of begs for a couple questions to be asked. Why don't the other critical infrastructures have mandatory standards? Also, is the Electric sector now generally acknowledged to be more secure than these other sectors? (Not risk, but result.) If so, is this increased reliability directly attributable to these mandatory standards?

2. The regularly updated, highly technical cybersecurity standards that govern electric utilities are drafted by the North American Energy Reliability Corporation, approved by the Federal Energy Regulatory Commission, and enforced by fines of up to $1 million per day per infraction.
   

It's true the standards have been updated several times. Version 3 was in place from 2010 to 2016. I'm not sure that this meets a practical definition of “regular updates” given the pace of change in information technology.

3. The process for crafting cybersecurity standards for utilities has provided, and continues to provide, a solid foundation for strengthening the industry’s security posture and allowed standards to evolve with constantly changing threats.

Lest we forget, these standards are reliability standards. Cybersecurity (protection from attack) is an aspect of reliability. It's good that the process exists to update these standards, however slow and cumbersome it may be.

4. Standards alone are not enough to protect the grid. That’s why the American Public Power Association and our member utilities have worked to develop close partnerships with others in the industry and the federal government. We share threat information to prepare for and respond to cyber attacks.

Amen, preach it! Standards rely upon voluntary compliance (even in mandatory schemes, you can't possible enforce everything without a great deal of goodwill and honest effort from the participants in the system).Too, standards are always compromised by conflicting interests. They must be a low bar to be universally applicable, and must be universal to be legal (but your specific circumstances or mine may really need more than just a minimal approach).

5. The Association recently signed a three-year cooperative agreement with the Department of Energy for up to $7.5 million to help public power utilities better understand and implement cybersecurity protections, resiliency, and advanced control concepts.

Training is always a good idea. Even better is cross-training. The electric utility industry seems to have a “not-invented-here” mindset that dismisses lessons and parallels from outside of the niche industry. We also have a reluctance to modify the approach to cyber-physical “operations technology”. Vendors have slipped behind in providing security controls for these types of devices, and the time-sensitive nature of some functions makes it problematic to add more devices in front of them.

To address the not-invented-here problem, NERC can work to incorporate NIST's work and that of other standards bodies into the standards drafting process. As the only mandatory, enforceable regulatory scheme in the Critical Sectors, it's tough to proceed without sometimes nailing down precise definitions and meanings, because lawsuits and immense fines may hinge upon a misplaced comma or an incautious throw-away phrase. However, “inside baseball” jargon should be avoided whenever possible. NERC needs to avoid adding terms to the NERC glossary which don't match commonly-understood usage in other IT security contexts. An IT Security professional who comes from outside the electric utility industry should be able to understand and apply CIP standards without an historical dissertation for context, or learning a new language of tortured and twisted definitions.

I like that "resilience" (corrected for the terrible sin against grammar) is mentioned in the article, but oddly enough this term, which is ubiquitous in disaster and business continuity planning disciplines across the world, doesn't feature in NERC CIP standards. FERC's approach to risk management doesn't really address that, at least not in NERC CIP Cybersecurity standards. 

Indeed, as I've had pointed out to me multiple times by NERC staff, FERC's position is that acceptance of risk is not allowable at the entity level (FERC Order 706, Section 139, Para. 154). However, an integral part of widely accepted resilience strategies is to acknowledge residual risks and plan for their possible occurrence with graceful failure modes and scope limitations as a risk mitigation tactic. It doesn't seem practical to get the ERO or Regional Entities to approve residual risk- there's no incentive for them to do so. They bear none of the costs of compliance and (impossible to achieve) risk elimination, but could be (almost certainly would be) blamed for a security breach that appears to be related to an explicitly accepted risk.

Things that make you go "Hmmm... "