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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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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Deep Dive Patrick Miller Deep Dive Patrick Miller

Claude Mythos and the OT Threat Horizon: What Utility Operators Need to Know Now

Anthropic's Claude Mythos can autonomously discover zero-day vulnerabilities across every major OS and browser, and the same codebases run in OT/SCADA environments. This post breaks down why Mythos-class AI exploitation tools directly implicate utility operators, which NERC CIP obligations are already in play, and what actions defenders should take before the patch window closes.

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Policy Pulse Patrick Miller Policy Pulse Patrick Miller

NERC's New INSM Regulation: Assessing Impact and Ambiguity

The recent draft release of NERC's new CIP Standard for Internal Network Security Monitoring (INSM) sparks a conversation filled with anticipation and skepticism. With directives from FERC Order 887 echoing in its language, the draft attempts to navigate through the challenges of creating a new regulation to address situations where vendors or individuals with authorized access are considered secure and trustworthy but could still introduce a cybersecurity risk.

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