NERC did not revise the CIP Standards for the cloud. It forked them. Project 2023-09 introduces a parallel 100-Series, an entity can elect into per system, built on a new foundation called BES Cyber Services and Systems (BCSS), with System Security Plans replacing asset lists and Cyber Security Zones replacing the Electronic Security Perimeter. Here is how the parallel track works, what the first drafts actually say, and the open problems worth commenting on before August 21.