Ampyx Cyber Blog

The Intersection of Regulation & Resilience

Cyber on Tap, Part Two: New York's Water Cybersecurity Regulation Is Now in Force
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Cyber on Tap, Part Two: New York's Water Cybersecurity Regulation Is Now in Force

New York's Appendix 5-E cybersecurity regulation for public water systems took effect March 11, 2026, making it the first mandatory, enforceable water cybersecurity framework in the country. This post covers who is in scope, what is required, when it is due, and what resources are available to help. It also examines what New York's action means in the context of a federal policy environment that is actively stepping back from sector-specific cybersecurity regulation.

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Industry Recognition: Patrick Miller Inducted into Industrial Cyber Hall of Fame
Ampyx Arc Patrick Miller Ampyx Arc Patrick Miller

Industry Recognition: Patrick Miller Inducted into Industrial Cyber Hall of Fame

Ampyx Cyber President and CEO Patrick Miller has been inducted into the Industrial Cyber Hall of Fame, joining a distinguished group of practitioners who helped define industrial cybersecurity as a discipline. The recognition highlights over three decades of work in grid security, NERC CIP development, and critical infrastructure protection around the globe.

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National Cyber Strategy: What It Means for Critical Infrastructure
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

National Cyber Strategy: What It Means for Critical Infrastructure

The Trump administration released its long-awaited National Cyber Strategy. Six pages, six pillars, and a clear signal that federal cyber policy is shifting toward offensive posture and regulatory streamlining. For critical infrastructure operators, the document raises more questions than it answers. Here is what it says, what it doesn't, and what you should do about it.

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Redesigning the Machine: NERC Board Accepts Transformational Standards Modernization Plan
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Redesigning the Machine: NERC Board Accepts Transformational Standards Modernization Plan

The NERC Board has approved a historic transformation of the standards development process to meet the speed of the modern grid. Aiming for a 12–18 month timeline, the new framework re-engineers how NERC addresses risks from data centers, IBRs, and VPPs. Read our deep dive into the 2027 roadmap, the new SME pool, and the upcoming shift in voting eligibility.

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Humans, Engineering Shifts, Required Investment, and Commitment for Operational Security
Deep Dive Patrick Miller Deep Dive Patrick Miller

Humans, Engineering Shifts, Required Investment, and Commitment for Operational Security

New secure connectivity guidance describes a greenfield target architecture, but most OT environments are brownfield reality. True resilience isn't achieved through technology alone. Human expertise, manual operating capability, physical engineering controls, and sustained investment are equally critical. Without these foundations, digital security layers risk becoming expensive new failure modes.

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How CMEP Version 8 Reshapes NERC’s Compliance Model
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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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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