Ampyx Cyber Blog

The Intersection of Regulation & Resilience

Protocol Converters: The 2023 SAR Just Got Validated (Again)
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Protocol Converters: The 2023 SAR Just Got Validated (Again)

The 2023 NERC SAR asked whether protocol converters belong inside CIP-002. A new disclosure of 22 CVEs in serial-to-Ethernet hardware, set against a decade of advisories across the category, settles the question. The categorization debate now has its empirical record, and asset owners have CIP-007 R2 and CIP-013 work to do that does not wait for the standard.

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FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do

FERC unanimously approved Order Nos. 918 and 919 on March 19, 2026, finalizing CIP virtualization standards and new low-impact BES Cyber System controls, plus an updated "Control Center" definition. All CIP-registered entities are affected. Implementation windows are 24 and 36 months respectively. Compliance programs should begin gap assessments now.

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ERO CMEP 2026: Oversight in the Age of Transformation
Policy Pulse Patrick Miller Policy Pulse 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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FERC 2025 CIP Audit Findings: DER Impact Ratings, Vendor Oversight Gaps, and Cloud Compliance Risk
Policy Pulse Patrick Miller Policy Pulse 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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CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12
Deep Dive Patrick Miller Deep Dive 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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NERC CIP-002 Standards Authorization Request - Project 2021-03
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

NERC CIP-002 Standards Authorization Request - Project 2021-03

NERC’s CIP-002 Project 2021-03 (Phase 2) introduces key updates to improve clarity and consistency in identifying and classifying BES Cyber Systems. The revisions address long-standing ambiguities by clarifying functional entity roles, refining the treatment of communication protocol converters, revising Criterion 1.3 to establish objective criteria for high-impact control centers, and expanding Criterion 2.6 to include control centers operated by Generator Operators and Transmission Owners. These changes aim to eliminate gaps in protection, align risk-based categorizations across all entities, and support more consistent compliance with CIP standards.

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FERC Staff Report Offers Lessons Learned from 2024 CIP Audits: What You Need to Know
Deep Dive Patrick Miller Deep Dive Patrick Miller

FERC Staff Report Offers Lessons Learned from 2024 CIP Audits: What You Need to Know

In its 2024 CIP audit report, the Federal Energy Regulatory Commission (FERC) shared critical lessons learned from the latest round of reliability audits, revealing key areas where NERC-registered entities can strengthen their security posture. While many organizations successfully met compliance requirements, the report highlighted specific gaps in asset categorization, control center segmentation, and data protection that could pose significant operational risks.

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Inverter-Based Resources - Guide to Potential NERC CIP Impacts of Upcoming Regulatory Changes
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Inverter-Based Resources - Guide to Potential NERC CIP Impacts of Upcoming Regulatory Changes

Upcoming NERC regulatory changes are expected to result in a significant increase in registrations of inverter-based resources, resulting in the likelihood of control centers to be categorized as North American Electrical Reliability Corporation (NERC) Critical Infrastructure Protection (CIP) Medium-Impact Control Centers and/or Low-Impact Control Centers and correspondingly to meet the relevant NERC CIP requirements.

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