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

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

Beyond the Checklist: The Place of Internal Controls in NERC CIP Compliance Programs

NERC CIP compliance is no longer a checklist exercise. Internal controls are now how the ERO Enterprise measures whether an entity can sustain compliance over time. This post breaks down what internal controls are, the preventive, detective, and corrective types, how entities test and evidence them, and how WECC's ICDCT and the December 2025 ERO Guide put controls at the center of audit scoping.

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Deep Dive Patrick Miller Deep Dive Patrick Miller

Using the Work of Others in NERC CIP and O&P Compliance

The work of others lets you lean on someone else's assessment as compliance evidence. It does not transfer accountability. This breakdown maps the ERO guidance stack, the two-part test auditors apply, worked examples for CIP-013 vendor assessments and BCSI in the cloud, the FERC FY2025 findings on delegation gone wrong, and the audit prep questions to answer first.

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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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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Understanding NERC's CIP-004-7 and CIP-011-3: A Deep Dive into BCSI Access, Cloud Challenges, and Encryption

Stay ahead of the curve with a comprehensive overview of NERC's new Critical Infrastructure Protection (CIP) standards, CIP-004-7 and CIP-011-3, set to be effective from January 1st, 2024. Understand the pivotal changes concerning BES Cyber System Information (BCSI) access, the nuances of cloud BCSI, and the strategic choices around encryption.

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