CIP-006-6 – Cyber Security – Physical Security of BES Cyber Systems

Purpose

To manage physical access to Bulk Electric System (BES) Cyber Systems by  specifying a physical security plan in support of protecting BES Cyber Systems against compromise that could lead to misoperation or instability in the BES.

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 (SPS) or Remedial Action Scheme (RAS) where the SPS or RAS 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

4.1.5 Interchange Coordinator or Interchange Authority

4.1.6 Reliability Coordinator

4.1.7 Transmission Operator

4.1.8 Transmission Owner

4.2. Facilities

For the purpose of the requirements contained herein, the following Facilities, systems, and equipment owned by each Responsible Entity in 4.1 above are those to which these requirements are applicable. For requirements in this standard where a specific type of Facilities, system, or equipment or subset of Facilities, systems, and equipment are applicable, these are specified explicitly.

4.2.1. Distribution Provider: One or more of the following Facilities, systems and equipment owned by the Distribution Provider for the protection or restoration of the BES:

4.2.1.1. Each UFLS or UVLS System that:

4.2.1.1.1. is part of a Load shedding program that is subject to one or more requirements in a NERC or Regional Reliability Standard; and

4.2.1.1.2. performs automatic Load shedding under a common control system owned by the Responsible Entity, without human operator initiation, of 300 MW or more.

4.2.1.2. 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.

4.2.1.3. 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.

4.2.1.4. 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.

4.2.2 Responsible Entities listed in 4.1 other than Distribution Providers

All BES Facilities.

4.2.3 Exemptions: The following are exempt from Standard CIP-006-6:

4.2.3.1 Cyber Assets at Facilities regulated by the Canadian Nuclear Safety Commission.

4.2.3.2 Cyber Assets associated with communication networks and data communication links between discrete Electronic Security Perimeters (ESPs).

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.

4.2.3.5 Responsible Entities that identify that they have no BES Cyber Systems categorized as high impact or medium impact according to the CIP-002-5.1 identification and categorization processes.

5. Effective Dates:

See Implementation Plan for CIP-006-6.

6. Background:

Standard CIP-006 exists as part of a suite of CIP Standards related to cyber security,  which require the initial identification and categorization of BES Cyber Systems and require a minimum level of organizational, operational and procedural controls to mitigate risk to BES Cyber Systems.

Most requirements open with, “Each Responsible Entity shall implement one or more documented [processes, plan, etc.] that include the applicable items in [Table Reference].”  The referenced table requires the applicable items in the procedures for the requirement’s common subject matter.

The term documented processes refers to a set of required instructions specific to the Responsible Entity and to achieve a specific outcome. This term does not imply any particular naming or approval structure beyond what is stated in the requirements. An entity should include as much as it believes necessary in their documented processes, but they must address the applicable requirements in the table.

The terms program and plan are sometimes used in place of documented processes where it makes sense and is commonly understood. For example, documented processes describing a response are typically referred to as plans (i.e., incident response plans and recovery plans). Likewise, a security plan can describe an approach involving multiple procedures to address a broad subject matter.

Similarly, the term program may refer to the organization’s overall implementation of its policies, plans, and procedures involving a subject matter. Examples in the standards include the personnel risk assessment program and the personnel training program. The full implementation of the CIP Cyber Security Reliability Standards could also be referred to as a program. However, the terms program and plan do not imply any additional requirements beyond what is stated in the standards.

Responsible Entities can implement common controls that meet requirements for multiple high and medium impact BES Cyber Systems.  For example, a single training program could meet the requirements for training personnel across multiple BES Cyber Systems.

Measures for the initial requirement are simply the documented processes themselves.  Measures in the table rows provide examples of evidence to show documentation and implementation of applicable items in the documented processes. These measures serve to provide guidance to entities in acceptable records of compliance and should not be viewed as an all-inclusive list.

Throughout the standards, unless otherwise stated, bulleted items in the requirements and measures 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 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.

“Applicable Systems” Columns in Tables:

Each table has an “Applicable Systems” column to further define the scope of systems to which a specific requirement row applies. The CSO706 SDT adapted this concept from the National Institute of Standards and Technology (“NIST”) Risk Management Framework as a way of applying requirements more appropriately based on impact and connectivity characteristics. The following conventions are used in the “Applicable Systems” column as described.

  • High Impact BES Cyber Systems – Applies to BES Cyber Systems categorized as high impact according to the CIP-002-5 identification and categorization processes.
  • Medium Impact BES Cyber Systems – Applies to each BES Cyber Systems categorized as medium impact according to the CIP-002-5 identification and categorization processes.
  • Medium Impact BES Cyber Systems without External Routable Connectivity – Only applies to medium impact BES Cyber Systems without External Routable Connectivity.
  • Medium Impact BES Cyber Systems with External Routable Connectivity – Only applies to medium impact BES Cyber Systems with External Routable Connectivity. This also excludes Cyber Assets in the BES Cyber System that cannot be directly accessed through External Routable Connectivity.
  • Electronic Access Control or Monitoring Systems (EACMS) – Applies to each Electronic Access Control or Monitoring System associated with a referenced high impact BES Cyber System or medium impact BES Cyber System.  Examples may include, but are not limited to, firewalls, authentication servers, and log monitoring and alerting systems.
  • Physical Access Control Systems (PACS) – Applies to each Physical Access Control System associated with a referenced high impact BES Cyber System or medium mpact BES Cyber System.
  • Protected Cyber Assets (PCA) – Applies to each Protected Cyber Asset associated with a referenced high impact BES Cyber System or medium impact BES Cyber System.
  • Locally mounted hardware or devices at the Physical Security Perimeter – Applies to the locally mounted hardware or devices (e.g. such as motion sensors, electronic lock control mechanisms, and badge readers) at a Physical Security Perimeter associated with a referenced high impact BES Cyber System or medium impact BES Cyber System with External Routable Connectivity, and that does not contain or store access control information or independently perform access authentication.  These hardware and devices are excluded in the definition of Physical Access Control Systems.

Requirements and Measures

R1. Each Responsible Entity shall implement one or more documented physical security plan(s) that collectively include all of the applicable requirement parts in CIP-006-6 Table R1 – Physical Security Plan. [Violation Risk Factor: Medium] [Time Horizon: Long Term Planning and Same Day Operations].

M1. Evidence must include each of the documented physical security plans that collectively include all of the applicable requirement parts in CIP-006-6 Table R1 – Physical Security Plan and additional evidence to demonstrate implementation of the plan or plans as described in the Measures column of the table.

CIP-006-6 Table R1 – Physical Security Plan

PartApplicable SystemsRequirementsMeasures
1.1Medium Impact BES Cyber Systems without External Routable Connectivity

Physical Access Control Systems (PACS) associated with:
  • High Impact BES Cyber Systems, or


  • Medium Impact BES Cyber Systems with External Routable Connectivity
  • Define operational or procedural controls to restrict physical access.An example of evidence may include, but is not limited to, documentation that operational or procedural controls exist.
    1.2Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Utilize at least one physical access control to allow unescorted physical access into each applicable Physical Security Perimeter to only those individuals who have authorized unescorted physical access.An example of evidence may include, but is not limited to, language in the physical security plan that describes each Physical Security Perimeter and how unescorted physical access is controlled by one or more different methods and proof that unescorted physical access is restricted to only authorized individuals, such as a list of authorized individuals accompanied by access logs
    1.3High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA
    Where technically feasible, utilize two or more different physical access controls (this does not require two completely independent physical access control systems) to collectively allow unescorted physical access into Physical Security Perimeters to only those individuals who have authorized unescorted physical access.An example of evidence may include, but is not limited to, language in the physical security plan that describes the Physical Security Perimeters and how unescorted physical access is controlled by two or more different methods and proof that unescorted physical access is restricted to only authorized individuals, such as a list of authorized individuals accompanied by access logs.
    1.4High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Monitor for unauthorized access through a physical access point into a Physical Security Perimeter.An example of evidence may include, but is not limited to, documentation of controls that monitor for unauthorized access through a physical access point into a Physical Security Perimeter.
    1.5High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Issue an alarm or alert in response to detected unauthorized access through a physical access point into a Physical Security Perimeter to the personnel identified in the BES Cyber Security Incident response plan within 15 minutes of detection.An example of evidence may include, but is not limited to, language in the physical security plan that describes the issuance of an alarm or alert in response to unauthorized access through a physical access control into a Physical Security Perimeter and additional evidence that the alarm or alert was issued and communicated as identified in the BES Cyber Security Incident Response Plan, such as manual or electronic alarm or alert logs, cell phone or pager logs, or other evidence that documents that the alarm or alert was generated and communicated.
    1.6Physical Access Control Systems (PACS) associated with:
  • High Impact BES Cyber Systems, or


  • Medium Impact BES Cyber Systems with External Routable Connectivity
  • Monitor each Physical Access Control System for unauthorized physical access to a Physical Access Control System.An example of evidence may include, but is not limited to, documentation of controls that monitor for unauthorized physical access to a PACS.
    1.7Physical Access Control Systems (PACS) associated with:
  • High Impact BES Cyber Systems, or


  • Medium Impact BES Cyber Systems with External Routable Connectivity
  • Issue an alarm or alert in response to detected unauthorized physical access to a Physical Access Control System to the personnel identified in the BES Cyber Security Incident response plan within 15 minutes of the detection.An example of evidence may include, but is not limited to, language in the physical security plan that describes the issuance of an alarm or alert in response to unauthorized physical access to Physical Access Control Systems and additional evidence that the alarm or alerts was issued and communicated as identified in the BES Cyber Security Incident Response Plan, such as alarm or alert logs, cell phone or pager logs, or other evidence that the alarm or alert was generated and communicated.
    1.8High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Log (through automated means or by personnel who control entry) entry of each individual with authorized unescorted physical access into each Physical Security Perimeter, with information to identify the individual and date and time of entry.An example of evidence may include, but is not limited to, language in the physical security plan that describes logging and recording of physical entry into each Physical Security Perimeter and additional evidence to demonstrate that this logging has been implemented, such as logs of physical access into Physical Security Perimeters that show the individual and the date and time of entry into Physical Security Perimeter.
    1.9High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Retain physical access logs of entry of individuals with authorized unescorted physical access into each Physical Security Perimeter for at least ninety calendar days.An example of evidence may include, but is not limited to, dated documentation such as logs of physical access into Physical Security Perimeters that show the date and time of entry into Physical Security Perimeter.
    1.10High Impact BES Cyber Systems and their associated:
  • PCA


  • Medium Impact BES Cyber Systems at Control Centers and their associated:
  • PCA
  • Restrict physical access to cabling and other nonprogrammable communication components used for connection between applicable Cyber Assets within the same Electronic Security Perimeter in those instances when such cabling and components are located outside of a Physical Security Perimeter.

    Where physical access restrictions to such cabling and components are not implemented, the Responsible Entity shall document and implement one or more of the following:
  • encryption of data that transits such cabling and components; or

  • mmonitoring the status of the communication link composed of such cabling and components and issuing an alarm or alert in response to detected communication failures to the personnel identified in the BES Cyber Security Incident response plan within 15 minutes of detection; or

  • an equally effective logical protection.
  • An example of evidence may include, but is not limited to, records of the Responsible Entity’s implementation of the physical access restrictions (e.g., cabling and components secured through conduit or secured cable trays) encryption, monitoring, or equally effective logical protections.

    R2. Each Responsible Entity shall implement one or more documented visitor control program(s) that include each of the applicable requirement parts in CIP-006-6 Table R2 – Visitor Control Program. [Violation Risk Factor: Medium] [Time Horizon: Same Day Operations.]  

    M2.  Evidence must include one or more documented visitor control programs that collectively include each of the applicable requirement parts in CIP-006-6 Table R2 – Visitor Control Program and additional evidence to demonstrate implementation as described in the Measures column of the table.

    CIP-006-6 Table R2 – Visitor Control Program

    PartApplicable SystemsRequirementsMeasures
    2.1High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Require continuous escorted access of visitors (individuals who are provided access but are not authorized for unescorted physical access) within each Physical Security Perimeter, except during CIP Exceptional Circumstances.An example of evidence may include, but is not limited to, language in a visitor control program that requires continuous escorted access of visitors within Physical Security Perimeters and additional evidence to demonstrate that the process was implemented, such as visitor logs.
    2.2High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Require manual or automated logging of visitor entry into and exit from the Physical Security Perimeter that includes date and time of the initial entry and last exit, the visitor’s name, and the name of an individual point of contact responsible for the visitor, except during CIP Exceptional Circumstances.An example of evidence may include, but is not limited to, language in a visitor control program that requires continuous escorted access of visitors within Physical Security Perimeters and additional evidence to demonstrate that the process was implemented, such as dated visitor logs that include the required information.
    2.3High Impact BES Cyber Systems and their associated:
    1. EACMS; and
    2. PCA

    Medium Impact BES Cyber Systems with External Routable Connectivity and their associated:
    1. EACMS; and
    2. PCA
    Retain visitor logs for at least ninety calendar days.An example of evidence may include, but is not limited to, documentation showing logs have been retained for at least ninety calendar days.

    R3. Each Responsible Entity shall implement one or more documented Physical Access Control System maintenance and testing  program(s) that collectively include each of the applicable requirement parts in CIP-006-6 Table R3 – Maintenance and Testing Program. [Violation Risk Factor: Medium] [Time Horizon: Long Term Planning].

     M3. Evidence must include each of the documented Physical Access Control System maintenance and testing programs that collectively include each of the applicable requirement parts in CIP-006-6 Table R3 – Maintenance and Testing Program and additional evidence to demonstrate implementation as described in the Measures column of the table.

    CIP-006-6 Table R3 – Physical Access Control System Maintenance and Testing Program

    PartApplicable SystemsRequirementsMeasures
    3.1Physical Access Control Systems (PACS) associated with:
  • High Impact BES Cyber Systems, or

  • Medium Impact BES Cyber Systems with External Routable Connectivity


  • Locally mounted hardware or devices at the Physical Security Perimeter associated with:
  • High Impact BES Cyber Systems, or

  • Medium Impact BES Cyber Systems with External Routable Connectivity
  • Maintenance and testing of each Physical Access Control System and locally mounted hardware or devices at the Physical Security Perimeter at least once every 24 calendar months to ensure they function properly.An example of evidence may include, but is not limited to, a maintenance and testing program that provides for testing each Physical Access Control System and locally mounted hardware or devices associated with each applicable Physical Security Perimeter at least once every 24 calendar months and additional evidence to demonstrate that this testing was done, such as dated maintenance records, or other documentation showing testing and maintenance has been performed on each applicable device or system at least once every 24 calendar months.

    1. Compliance Monitoring Process

    1.1. Compliance Enforcement Authority:

    As defined in the NERC Rules of Procedure, “Compliance Enforcement Authority” (CEA) means NERC or the Regional Entity in their respective roles of monitoring and enforcing compliance with the NERC Reliability Standards.

    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.
    • 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 Violation Investigations
    • Self-Reporting
    • Complaints

    1.4. Additional Compliance Information

    None


    Guidelines and Technical Basis

    Section 4 – Scope of Applicability of the CIP Cyber Security Standards

    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.  As specified in the exemption section 4.2.3.5, this standard does not apply to Responsible Entities that do not have High Impact or Medium Impact BES Cyber Systems under CIP-002-5.1’s categorization. In addition to the set of BES Facilities, Control Centers, and other systems and equipment, the list includes the 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.

    General:

    While the focus of this Reliability Standard has shifted away from the definition and  management of a completely enclosed “six-wall” boundary, it is expected that in many instances a six-wall boundary will remain a primary mechanism for controlling, alerting, and logging access to BES Cyber Systems.  Taken together, these controls outlined below will effectively constitute the physical security plan to manage physical access to BES Cyber Systems.

    Requirement R1:

    Methods of physical access control include:

    • Card Key:  A means of electronic access where the access rights of the card holder are predefined in a computer database. Access rights may differ from one perimeter to another.
    • Special Locks:  These include, but are not limited to, locks with “restricted key” systems, magnetic locks that can be operated remotely, and “man-trap” systems.
    • Security Personnel:  Personnel responsible for controlling physical access who may reside on-site or at a monitoring station.
    • Other Authentication Devices:  Biometric, keypad, token, or other equivalent devices that control physical access into the Physical Security Perimeter.

    Methods to monitor physical access include:

    • Alarm Systems:  Systems that alarm to indicate interior motion or when a door, gate, or  window has been opened without authorization.  These alarms must provide for notification within 15 minutes to individuals responsible for response.
    • Human Observation of Access Points: Monitoring of physical access points by security personnel who are also controlling physical access.

    Methods to log physical access include:

    • Computerized Logging:  Electronic logs produced by the Responsible Entity’s selected access  control and alerting method. ? Video Recording:  Electronic capture of video images of sufficient quality to determine  identity.
    • Manual Logging:  A log book or sign-in sheet, or other record of physical access maintained  by security or other personnel authorized to control and monitor physical access.

    The FERC Order No. 706, Paragraph 572, directive discussed utilizing two or more different and  complementary physical access controls to provide defense in depth.  It does not require two or more Physical Security Perimeters, nor does it exclude the use of layered perimeters.  Use of two-factor authentication would be acceptable at the same entry points for a non-layered single perimeter.  For example, controls for a sole perimeter could include either a combination of card key and pin code (something you know and something you have), or a card key and biometric scanner (something you have and something you are), or a physical key in combination with a guard-monitored remote camera and door release, where the “guard” has adequate information to authenticate the person the guard is observing or talking to prior to permitting access (something you have and something you are).  The two-factor authentication could be implemented using a single Physical Access Control System but more than one authentication method must be utilized.  For physically layered protection, a locked gate in combination with a locked control-building could be acceptable, provided no single authenticator (e.g., key or card key) would provide access through both.

    Entities may choose for certain PACS to reside in a PSP controlling access to applicable BES Cyber Systems. For these PACS, there is no additional obligation to comply with Requirement Parts 1.1, 1.6 and 1.7 beyond what is already required for the PSP.

    The new requirement part CIP-006-6, Requirement R1, Part 1.10 responds to the directive found in FERC Order No. 791, Paragraph 150.  The requirement intends to protect cabling and nonprogrammable communication components that are within an ESP, but extend outside of a PSP.  This protection, similar to the FERC Approved NERC Petition on the interpretation on CIP006-2 from PacifiCorp, must be accomplished either by physically protecting the cabling and components that leave a PSP (such as by conduit or secured cable trays) or through data  encryption, circuit monitoring, or equally effective logical protections.  It is intended that the physical protections reduce the possibility of tampering or allowing direct access to the nonprogrammable devices.  Conduit, secured cable trays, and secured communication closets are examples of these types of protections. These physical security measures should be implemented in such a way that they would provide some mechanism to detect or recognize that someone could have tampered with the cabling and non-programmable components.  This could be something as simple as a padlock on a communications closet where the entity would recognize if the padlock had been cut off. Alternatively, this protection may also be accomplished through the use of armored cabling or via the stainless steel or aluminum tube protecting the fiber inside an optical ground wire (OPGW) cable.  In using any of these methods, care should be taken to protect the entire length of the cabling including any termination points that may be outside of a defined PSP.

    This requirement part only covers those portions of cabling and nonprogrammable communications components that are located outside of the PSP, but inside the ESP.  Where this cabling and non-programmable communications components exist inside the PSP, this requirement part no longer applies.

    The requirement focuses on physical protection of the communications cabling and components as this is a requirement in a physical security standard and the gap in protection identified by FERC in Order 791 is one of physical protections.  However, the requirement part recognizes that there is more than one way to provide protection to communication cabling and nonprogrammable components.  In particular, the requirement provides a mechanism for entities to select an alternative to physical security protection that may be chosen in a situation where an entity cannot implement physical security or simply chooses not to implement physical security.  The entity is under no obligation to justify or explain why it chose logical protections over physical protections identified in the requirement.

    The alternative protective measures identified in the CIP-006-6 R1, Part 1.10 (encryption and circuit monitoring) were identified as acceptable alternatives in NERC petition of the PacifiCorp Interpretation of CIP-006-2 which was approved by FERC (RD10-13-000).  If an entity chooses to implement an “an equally effective logical protection” in lieu of one of the protection mechanisms identified in the standard, the entity would be expected to document how the protection is equally effective.  NERC explained in its petition of the PacifiCorp Interpretation of CIP-006-2 that the measures are relevant to access or physical tampering.  Therefore, the entity may choose to discuss how its protection may provide detection of tampering.  The entity may also choose to explain how its protection is equivalent to the other logical options identified in the standard in terms of the CIA triad (confidentiality, integrity, and availability).  The entity may find value in reviewing their plans prior to implementation with the regional entity, but there is no obligation to do so.

    The intent of the requirement is not to require physical protection of third party components, consistent with FERC Order 791-A.  The requirement allows flexibility in that the entity has control of how to design its ESP and also has the ability to extend its ESP outside its PSP via the logical mechanisms specified in CIP-006-6 Requirement 1, Part 1.10 such as encryption (which is an option specifically identified in FERC Order 791-A).   These mechanisms should provide sufficient protections to an entity’s BES Cyber Systems while not requiring controls to be implemented on third-party components when entities rely on leased third-party communications.

    In addition to the cabling, the components in scope of this requirement part are those components outside of a PSP that could otherwise be considered a BES Cyber Asset or Protected Cyber Asset except that they do not meet the definition of Cyber Asset because they are nonprogrammable.  Examples of these nonprogrammable components include, but are not limited to, unmanaged switches, hubs, patch panels, media converters, port savers, and couplers.

    Requirement R2:

    The logging of visitors should capture each visit of the individual and does not need to capture  each entry or exit during that visit.  This is meant to allow a visitor to temporarily exit the Physical Security Perimeter to obtain something they left in their vehicle or outside the area without requiring a new log entry for each and every entry during the visit.

    The SDT also determined that a point of contact should be documented who can provide additional details about the visit if questions arise in the future.  The point of contact could be the escort, but there is no need to document everyone that acted as an escort for the visitor.

    Requirement R3:

    This includes the testing of locally mounted hardware or devices used in controlling, alerting or  logging access to the Physical Security Perimeter.  This includes motion sensors, electronic lock control mechanisms, and badge readers which are not deemed to be part of the Physical Access Control System but are required for the protection of the BES Cyber Systems.

    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.

    Rationale for Requirement R1:

    Each Responsible Entity shall ensure that physical access to all BES Cyber Systems is restricted  and appropriately managed. Entities may choose for certain Physical Access Control Systems (PACS) to reside in a Physical Security Perimeter (PSP) controlling access to applicable BES Cyber Systems. For these PACS, there is no additional obligation to comply with Requirement R1, Parts 1.1, 1.6 and 1.7 beyond what is already required for the PSP.

    Regarding Requirement R1, Part 1.10, when cabling and other nonprogrammable components of a Control Center’s communication network cannot be secured in a PSP, steps must be taken to ensure the integrity of the BES Cyber Systems.  Exposed communication pathways outside of a PSP necessitate that physical or logical protections be installed to reduce the likelihood that man-in-the-middle attacks could compromise the integrity of their connected BES Cyber Assets or PCAs that are required to reside within PSPs.  While it is anticipated that priority consideration will be given to physically securing the cabling and nonprogrammable communications components, the SDT understands that configurations arise when physical access restrictions are not ideal and Responsible Entities are able to reasonably defend their physically exposed communications components through specific additional logical protections.

    Rationale for Requirement R2:

    To control when personnel without authorized unescorted physical access can be in any Physical Security Perimeters protecting BES Cyber Systems or Electronic Access Control or Monitoring Systems, as applicable in Table R2.

    Rationale for Requirement R3:  

    To ensure all Physical Access Control Systems and devices continue to function properly.


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