Ampyx Cyber Blog

The Intersection of Regulation & Resilience

From Spot Evaluations to Continuous Oversight: NERC’s New Internal Controls Model
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

From Spot Evaluations to Continuous Oversight: NERC’s New Internal Controls Model

NERC’s December 2025 ERO Enterprise Guide replaces the old ICE model with continuous, risk based internal control oversight embedded across CMEP and Joint Monitoring. This shift makes control design, evidence, and effectiveness a core driver of Compliance Oversight Plans (COPs), audit depth, and how the Regions measure compliance maturity.

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New Joint Agency Guidance: Secure Connectivity Principles for OT
Deep Dive Patrick Miller Deep Dive Patrick Miller

New Joint Agency Guidance: Secure Connectivity Principles for OT

A Five Eyes plus European intelligence coalition has published a new doctrine for securing OT connectivity against nation-state threats. This Deep Dive examines what the NCSC principles mean for utilities and industrial operators, what breaks in legacy environments, and the safety, cost, and engineering realities of moving from compliance-driven security to true operational resilience.

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Volt Typhoon and the Quiet Pre-Positioning of the U.S. Power Grid [Updated]
Deep Dive Patrick Miller Deep Dive Patrick Miller

Volt Typhoon and the Quiet Pre-Positioning of the U.S. Power Grid [Updated]

Volt Typhoon represents a quiet but strategic cyber threat to U.S. electric utilities, characterized by long-term access and persistence rather than immediate disruption. Rather than deploying malware, the actor relies on legitimate administrative tools to maintain durable access inside critical infrastructure networks. This blog examines what makes Volt Typhoon different and why early detection depends on behavioral context, not signatures.

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New NSA UEFI Guidance: Trust Starts Before the OS
Deep Dive Patrick Miller Deep Dive Patrick Miller

New NSA UEFI Guidance: Trust Starts Before the OS

UEFI Secure Boot is widely assumed to be enabled and enforcing, yet recent vulnerabilities show how easily trust at boot time can silently fail. NSA’s new guidance breaks down how Secure Boot actually works, where configurations commonly go wrong, and how organizations can validate and recover trust in the earliest stages of system startup.

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ERO CMEP 2026: Oversight in the Age of Transformation
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

ERO CMEP 2026: Oversight in the Age of Transformation

The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.

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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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Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management

FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.

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Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains

FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.

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Interconnection Gets Teeth: Virginia Puts Cyber into the Rulebook
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Interconnection Gets Teeth: Virginia Puts Cyber into the Rulebook

Virginia moves cyber into DER interconnection. State Corporation Commission (SCC) Staff proposes adopting IEEE 1547.3-2023 and the NARUC/DOE Baselines, requiring utilities to publish minimum cybersecurity standards, audit & report annually, and align Technical Interconnection (TIIR) settings for secure comms/ports. Bottom line: meeting utility cyber controls becomes a condition of interconnection.

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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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Skills Elevated: More Ways to Build Cyber Resilience
Skill Set Patrick Miller Skill Set Patrick Miller

Skills Elevated: More Ways to Build Cyber Resilience

Ampyx Cyber is expanding its training portfolio with new courses designed for utilities and critical infrastructure teams. From NERC CIP Bootcamp to OT vulnerability management and ICS packet analysis, our offerings provide more ways to build cyber resilience with practical, field-tested learning.

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CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12
Deep Dive Patrick Miller Deep Dive Patrick Miller

CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12

Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.

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Foundations for OT Cybersecurity: From Inventory to Impact
Deep Dive Patrick Miller Deep Dive Patrick Miller

Foundations for OT Cybersecurity: From Inventory to Impact

CISA’s new OT asset-inventory guidance puts structure behind “know your system.” This post translates it into action: a practical, prioritized field set and taxonomy you can implement now. We added a lightweight BIA overlay that links asset criticality to mission impact. We also show where to emphasize configuration baselines, change control, and logging to improve monitoring and decision quality.

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