From Firefighting to Foresight: Building CIP Programs for the Future Power Grid
By Jason SmitH
NERC calls grid reliability a “five-alarm fire.” With data centers, AI, and extreme weather straining capacity, CIP programs must evolve from reactive compliance to proactive resilience. This post outlines how utilities can strengthen controls, close documentation gaps, and build CIP programs ready for the future grid.
Overview
When NERC President Jim Robb calls grid reliability a “five alarm fire,” he is not exaggerating. He is describing the reality we all see in the field: tighter reserve margins, rapid load growth, and a system being pushed harder every year. The warning is not about collapse. It is about urgency. Reliability and security are now inseparable, and that means CIP programs must evolve just as fast as the grid itself.
The Pressure Points Behind the Warning
Robb told FERC that while the grid’s overall performance remains strong, its safety margin is shrinking. Demand from data centers and AI workloads is accelerating. Weather events are more extreme. Transmission projects are moving too slowly to keep up.
The Department of Energy estimates that by 2028, data centers alone could use up to 12 percent of U.S. electricity, compared to about 4.4 percent in 2023. That shift changes everything: how we plan, how we operate, and how we manage compliance. For compliance leaders, this means one clear takeaway: resilience is the new compliance baseline.
How This Pressure Translates to the CIP Framework
The current grid environment puts the CIP standards under new stress. Here is where the impact will be felt first.
CIP-002-5.1a: Categorization That Keeps Up With Growth
Risk: Expanding load centers and new interconnections are redefining impact ratings.
Action: Do not wait for the next review cycle. Update BES Cyber System impact assessments as soon as new large loads such as data centers, AI campuses, or industrial sites connect. Coordinate with system planners to keep asset categorization aligned with the real grid, not last year’s version of it.
CIP-003-8/9 Through CIP-009-6: Resilience as an Audit Expectation
Risk: When the grid is under stress, cyber or operational incidents escalate faster.
Action: Refresh your baseline controls and recovery testing. Design incident response scenarios that reflect simultaneous operational challenges such as load spikes, communication failures, weather impacts, and cyber events occurring together. Regulators would prefer to see realistic drills, not checkbox exercises.
CIP-005-7 and CIP-010-4: Managing Change in Fast Build Environments
Risk: Accelerated infrastructure projects introduce configuration risk and access exposure.
Action: Under CIP-010-4, tighten change authorization, validation, and baseline maintenance. Keep records current during every phase of a project regardless of whether it affects the defined elements requiring baseline updates per R1 part 1.1, even under time pressure. Under CIP-005-7, review temporary access controls to ensure contractors and integrators are managed with the same rigor as internal staff.
CIP-007-6 — Hardening the Cyber Hygiene Foundation
Risk: As the grid grows more complex and load growth accelerates, the number of devices, firmware versions, and configurations multiplies. Each one introduces new vulnerabilities that can be exploited faster than teams can patch if controls are not disciplined.
Action: Strengthen the fundamentals. Under CIP-007-6, validate that patch management programs are catching and applying vendor updates within required timelines. Cross reference your vulnerability assessments under CIP-010-4 to confirm nothing is falling through the cracks.
Ensure port hardening and service account management (Parts 1 and 5) remain consistent during rapid infrastructure expansion.
Verify logging and alerting controls (Part 4) still align with your baseline configurations after system upgrades or vendor changes.
Conduct a configuration drift review to make sure updates have not reopened deprecated ports or protocols.
Why It Matters: In a grid environment described as a five alarm fire, small lapses in basic system hardening can cascade into big reliability issues. CIP-007-6 is where operational security meets compliance discipline. When auditors or reliability coordinators look for assurance that the grid’s digital foundation is stable, they are often looking here first.
CIP-010-4 and CIP-013-2: Expanding the Supply Chain Defense
Risk: More vendors mean more firmware, patching, and communication channels to manage.
Action: Use CIP-010-4 R1 Part 1.6 and CIP-013-2 together to anchor your vulnerability and supplier oversight. Confirm vendor advisories are genuine, tested, and tracked through to mitigation. Build stronger partnerships between procurement, compliance and cyber risk management teams to keep oversight continuous.
CIP-014-3: Protecting New High Value Targets
Risk: Data center corridors and new substations create concentrated risk zones.
Action: Reevaluate physical security plans if your transmission footprint shifts to support new loads. Update modeling for cascading impacts and ensure new assets are covered under your CIP-014-3 strategy.
Cross Program Themes to Watch
| Theme | Compliance Impact | What to Do |
|---|---|---|
| Tight reserve margins | Heightened focus on operational resilience and recovery capability | Prove your incident and recovery testing aligns with real stress conditions |
| Rapid load growth | New assets may change impact ratings | Coordinate early with planning and document categorization logic |
| Fast transmission build outs | Frequent configuration and vendor changes | Strengthen CIP-010-4 change tracking and CIP-013-2 supplier monitoring |
| Expanding interdependencies | New failure modes through gas, telecom, or data infrastructure | Document interdependency analysis and integrate it into response planning |
Note: According to the U.S. Energy Information Administration (EIA), natural-gas-fired power generation accounted for approximately 42 % of U.S. net generation in 2024.
The Compliance Reality: Scrutiny Is Rising
FERC and NERC are clear: the grid’s risk profile has shifted from episodic to structural. Regulators will expect faster updates, higher evidence quality, and better documentation.
Now is the time to:
Eliminate lag between operational changes and baseline updates.
Modernize testing to include realistic multi threat scenarios.
Document decisions and notifications as if the audit has already started.
What Strong Programs Should Anticipate Doing
At Ampyx Cyber, we see leading entities taking proactive steps:
Conducting targeted readiness reviews of CIP-010-4 and CIP 008-6 controls tailored to fast changing environments.
Mapping infrastructure growth and third party activity to specific CIP risks.
Expanding tabletop and technical tests to simulate system stress and rapid response coordination.
This is not about reacting to regulation. It is about anticipating it. Reliability and security have become a shared mission between compliance and operations.
Closing Thought
When Jim Robb calls it a five alarm fire, he is not sounding panic. He is setting the tone for how we move forward. Our role is to turn that warning into readiness, to make sure the system bends without breaking. That starts with a CIP program that is proactive, resilient, and built for the grid we are heading toward, not the one we are leaving behind.
