Ampyx Cyber Blog

The Intersection of Resilience & Regulation

Policy Pulse Patrick Miller Policy Pulse Patrick Miller

NERC CMEP 2027: Security Becomes One Risk Element

The North American Electric Reliability Corporation's 2027 Compliance Monitoring and Enforcement Program Implementation Plan has five risk elements instead of seven. Most Critical Infrastructure Protection (CIP) requirements carry over from 2026, though CIP-012 comes off the list and aggregation of control and cloud storage of grid cyber information get new language.

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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

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

How CMEP Version 8 Reshapes NERC’s Compliance Model

The CMEP Version 8 does not rewrite NERC compliance, rather it stabilizes it. Building on years of evolution, the updated Manual reinforces risk-based oversight, professional judgment, technical competence, and enterprise consistency across all Reliability Standards. The result is a more mature, defensible compliance model that shapes how audits, enforcement, and reliability governance now operate.

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