Ampyx Cyber Blog

The Intersection of Regulation & Resilience

INSM Just Got Clearer: Key Takeaways from the NATF Guidance
Deep Dive Patrick Miller Deep Dive Patrick Miller

INSM Just Got Clearer: Key Takeaways from the NATF Guidance

NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.

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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-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

CIP-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope

FERC Order 907-A clarifies CIP-015 on shared networks. INSM must monitor only east-west traffic used for access monitoring of EACMS and PACS. Non-CIP assets and data flows are out of scope, even in mixed-use or commingled PACS/EACMS environments. Learn practical patterns to filter collection, segment analytics, and produce audit-ready evidence.

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CIP-015-1 INSM: A Practical Playbook
Deep Dive Patrick Miller Deep Dive Patrick Miller

CIP-015-1 INSM: A Practical Playbook

NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.

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FERC Finalizes INSM Standard: CIP-015-1 and the New Visibility Mandate for the Grid
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Finalizes INSM Standard: CIP-015-1 and the New Visibility Mandate for the Grid

On June 26, the Federal Energy Regulatory Commission issued Order No. 907, approving the new NERC Reliability Standard CIP-015-1: Cyber Security – Internal Network Security Monitoring (INSM). This marks a critical shift in how we approach cybersecurity within the Bulk Electric System. It also raises the bar significantly on what’s expected for visibility inside the network perimeter.

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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 Proposes New Standards for INSM: Internal Network Security Monitoring (CIP-015-1)
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

FERC Proposes New Standards for INSM: Internal Network Security Monitoring (CIP-015-1)

The Federal Energy Regulatory Commission (FERC) has issued a new Notice of Proposed Rulemaking (NOPR) under Docket No. RM24-7-000. This proposed rule seeks to approve NERC’s proposed Critical Infrastructure Protection (CIP) Reliability Standard CIP-015-1. The new standard focuses on Internal Network Security Monitoring (INSM) to detect and address cyber threats within the electronic security perimeter of the Bulk Electric System (BES).

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