NERC’s CIP Roadmap and the Future of Grid Cybersecurity

NERC’s new CIP Roadmap signals a major shift in how cyber risk will be regulated across the power grid. This Policy Pulse explains what NERC released, why it matters, what standards and guidance are coming next, and how utilities, generators, and grid operators should prepare for expanding CIP scope and enforcement.

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Patrick Miller
Volt Typhoon and the Quiet Pre-Positioning of the U.S. Power Grid

Volt Typhoon represents a quiet but strategic cyber threat to U.S. electric utilities, characterized by long-term access and persistence rather than immediate disruption. Rather than deploying malware, the actor relies on legitimate administrative tools to maintain durable access inside critical infrastructure networks. This blog examines what makes Volt Typhoon different and why early detection depends on behavioral context, not signatures.

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Patrick Miller
New NSA UEFI Guidance: Trust Starts Before the OS

UEFI Secure Boot is widely assumed to be enabled and enforcing, yet recent vulnerabilities show how easily trust at boot time can silently fail. NSA’s new guidance breaks down how Secure Boot actually works, where configurations commonly go wrong, and how organizations can validate and recover trust in the earliest stages of system startup.

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Patrick Miller
ERO CMEP 2026: Oversight in the Age of Transformation

The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.

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Patrick Miller
INSM Just Got Clearer: Key Takeaways from the NATF Guidance

NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.

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Patrick Miller
FERC 2025 CIP Audit Findings: DER Impact Ratings, Vendor Oversight Gaps, and Cloud Compliance Risk

FERC’s latest CIP audit lessons for 2025 highlight three rising compliance risks. Entities are undercounting DERs in GOP control center impact ratings, outsourcing compliance work without adequate oversight, and moving EACMS or PACS functions to the cloud without a defensible evidence path. These issues now represent real audit exposure across the US bulk power system.

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Patrick Miller
Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management

FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.

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Patrick Miller
Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains

FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.

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Patrick Miller
Interconnection Gets Teeth: Virginia Puts Cyber into the Rulebook

Virginia moves cyber into DER interconnection. State Corporation Commission (SCC) Staff proposes adopting IEEE 1547.3-2023 and the NARUC/DOE Baselines, requiring utilities to publish minimum cybersecurity standards, audit & report annually, and align Technical Interconnection (TIIR) settings for secure comms/ports. Bottom line: meeting utility cyber controls becomes a condition of interconnection.

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Patrick Miller
Skills Elevated: More Ways to Build Cyber Resilience

Ampyx Cyber is expanding its training portfolio with new courses designed for utilities and critical infrastructure teams. From NERC CIP Bootcamp to OT vulnerability management and ICS packet analysis, our offerings provide more ways to build cyber resilience with practical, field-tested learning.

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Patrick Miller
CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12

Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.

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Patrick Miller
Foundations for OT Cybersecurity: From Inventory to Impact

CISA’s new OT asset-inventory guidance puts structure behind “know your system.” This post translates it into action: a practical, prioritized field set and taxonomy you can implement now. We added a lightweight BIA overlay that links asset criticality to mission impact. We also show where to emphasize configuration baselines, change control, and logging to improve monitoring and decision quality.

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Patrick Miller
CIP-015-1 INSM: A Practical Playbook

NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.

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Patrick Miller