Chapter 1
What are the complications around securing digital operations for utilities?
OT cybersecurity for utilities is complicated by a number of factors.
A direct consequence of these advances is that the hardware, software and networks that were designed and deployed on a closed (segmented) network — inherently secure — are now operating in a connected network. As the number of connections increases, the attack surface expands, and we now have a complicated cybersecurity risk management challenge.
In OT environments, because the potential to disrupt the process that the OT device controls is the greatest risk, security processes should first focus on the control and availability of the OT and its communications media. Because the processes that the devices control are dependent upon precise sensor readings, the integrity of the information shared between the devices and the process computers is also critically important. The confidentiality of this information is generally not as relatively critical (at least not while the device remains in the possession of the utility). This prioritization does affect the defense mechanisms available and the speed of remediation efforts. For example, traditional network and application security technologies can add latency to critical real-time communications, which could affect the reliability of operations. Defending OT from cyber-attacks requires a different set of capabilities than those used to protect IT.
This is further complicated by the vendors. Often, technology manufacturers will not certify security technologies to work with their OT product lines due to the potential for disruption, which can result in voided warranties and violations of service contracts if unapproved security products are applied without vendor certification. In some cases, particularly in generation environments, the plant control processes are not only designed by the ICS manufacturer but also managed completely by the vendor, introducing challenges in adhering not only to standard security controls, such as remote access and removable media restrictions but even to personnel controls, such as background screening procedures.
As the cyber attack surface increases, so do the potential threat actors — such as a nation-state or terrorist motivated by a desire to inflict physical damage, a hacktivist motivated by unacceptable environmental practices, a disgruntled employee or contractor, ransomware gangs looking for a financial payout, a group of people undertaking a synchronized attack, or automated attacks carried out by machines. As each weapon is used, it has the potential of being packaged as an attack kit on the dark web and becoming available to a much broader set of less sophisticated actors. In July 2021, Gartner predicted that by 2025, cyber attackers will have weaponized OT environments to successfully harm or kill humans.¹
One of the more pertinent challenges today is the availability of skill sets to defend against sophisticated threat actors who are rapidly increasing their skill levels and the frequency of their attacks. According to the Department of Energy, History of ICS Cyber Incidents (December 2018), “Many of the threat actors targeting ICSs have advanced skills and knowledge. The defenders of these systems need to have equally advanced skills and knowledge.” Attracting and retaining such skills that are limited in availability and high in demand presents an enormous challenge for utilities.
Chapter 2
What should utilities do?
First and foremost, utilities need to understand the nature of the risk.
So, where does this leave us? First and foremost, we need to understand the nature of the risk. This is a business risk to the reliability of service and potentially to the safety of both employees and the public. This clarification is important as one starts to consider the accountability model and roles and responsibilities.
Secondly, regulatory compliance may not be sufficient to manage the business risk. Regulations, such as NERC CIP, are designed to protect the bulk electric system from a cascading regional blackout — they are not designed to protect an individual utility from a catastrophic event within its territory. Compliance is important, and it is mitigating some of the business risk — but is it mitigating the business risk to an acceptable level? Likely not.
Each utility needs to have an asset management program that provides visibility of the assets. The utility must analyze the consequence of a security event in different parts of its operations, the vulnerability of that part of the operations and the likelihood of a threat actor exploiting that vulnerability. Understanding the risk prioritization and exposure can then inform the level of actions that need to be considered. It also shifts resources to focus more on what matters most. Defense-in-depth control layers can be analyzed while making sure sufficient effort is allocated to detection and response — recognizing that a persistent, sophisticated actor may eventually navigate through the preventative controls. One can start to analyze the cost of actions against the level of risk reduction and find that “Goldilocks” balance. Memorializing the control expectations in risk-based policies and standards confirms communication of both the control expectations and the risk being accepted.
Finally — collaboration. No single person or function has all the information to make an informed decision. The business risk of reliability of service and safety is owned by operations. Operations is best informed about articulating the consequences of different levels of security disruption. In many cases, Operations will be responsible for performing control activities and serve as the first line of defense. Operations also owns the budget — either directly or indirectly — and is also mitigating other causes of service interruption. IT plays an important role: the IT network remains one of the most exploited vectors for OT cyber events, and IT is often responsible for managing some of the IT equipment on the OT networks. Security is best informed to assess the vulnerability and the likelihood of a threat actor exploiting the vulnerability. Security is also best informed on evaluating different mitigation strategies and making sure the right defense in depth is being considered.
Historically, an autocratic model of security telling the business what to do was an effective way to rapidly put in place basic hygiene. That model was effective for that time and that need. What got us to where we are today won’t be successful in getting us to where we need to be tomorrow. We need to get smarter about where we are spending our limited dollars. We need to engage the business more, explain the threats and our vulnerabilities, have the business explain the ramifications to its operations and get a consensus on how to best spend the limited funds. This approach is far more collaborative and positioned around business risk. It puts the ownership of security risk on all, and the security function becomes a business partner. Being valued as a business partner and brought to the table early in digital programs can help such programs be delivered securely. Getting this operating model right is not only important for the security function but also critical for the utility.
Related content
A similar article was published by T&D World in early February 2023.
The views reflected in this article are the views of the author and do not necessarily reflect the views of Ernst & Young LLP or other members of the global EY organization.
Summary
The utilities industry is undergoing a significant digital transformation to its operations. All the more reason they need to confirm that the digitization of operations is being done securely — and they need to address this now.
