Ampyx Cyber Blog

The Intersection of Resilience & Regulation

Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC's 2026 CIP Lessons Are an AI Change-Control Warning

A Federal Energy Regulatory Commission (FERC) staff report on 2026 Critical Infrastructure Protection (CIP) audits found capability beyond what existing reviews had assessed, in phased generation, shared control centers, and artificial intelligence (AI) tools. Read as a change-control problem, it raises the question of which AI updates should reopen an access approval or a CIP-002 categorization.

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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC 2026 CIP Audit Findings: Generator Registration, Aggregated Control, and AI Tool Access

The Federal Energy Regulatory Commission (FERC) staff report on its 2026 Critical Infrastructure Protection (CIP) audits found new generation running before it was registered, aggregated control of generation sitting with affiliates and vendors, and artificial intelligence (AI) tools inside CIP-networked environments. Two of the three lessons are categorization problems again.

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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

New York Ordered Utilities to Inventory Their AI. What Happens When It Changes?

New York has ordered 12 utilities to inventory every artificial intelligence (AI) use case by November 16, and Arizona is collecting similar information through a docket. Both capture AI at one point in time. Keirsten Brager looks at keeping that inventory accurate as models and vendors change, and at the North American Electric Reliability Corporation (NERC) controls that already do this work.

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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

When AI Changes Without a Change Request

On September 28 and 29 I will be at The Utility Change Conference West 2026 in Phoenix to talk about the artificial intelligence (AI) changes that never enter a utility's change process. A vendor feature toggle or a model update can alter what a tool reaches and how it behaves while the configuration baseline shows nothing. This preview walks through the questions those changes raise under the North American Electric Reliability Corporation (NERC) Critical Infrastructure Protection (CIP) standards, using three recent incidents outside the utility sector as context.

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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Who Owns the Risk? The AI Reliability Boundary Assessment Questions

An AI decision-support platform fails at 2:07 on a weekday afternoon. At 2:22 the fifteen-minute reliability window closes and the vendor is still investigating. This is the full question set from the CYBR.SEC.CON talk, forty questions across four NERC CIP standards plus the ownership map behind them. You score your own answers, and nothing on this page collects anything.

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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

The AI Reliability Boundary: A Black Hat Debrief for the Grid

Almost every conversation at Black Hat came back to AI, and almost every pitch assumed the answer to an AI problem is another product. In the grid, that assumption does not hold. Keirsten Brager's debrief on what the show floor missed, why governance is not a document, and why AI is not automatically out of scope for NERC's Critical Infrastructure Protection standards. It closes with the questions to answer before your next vendor demo.

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