Virtualization and Cloud Computing Services, 11363-11366 [2020-03928]
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Federal Register / Vol. 85, No. 39 / Thursday, February 27, 2020 / Notices
DEPARTMENT OF ENERGY
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
Federal Energy Regulatory
Commission
Combined Notice of Filings
[Docket No. ID–8853–000]
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McCormick, Brian A.; Notice of Filing
Take notice that on February 19, 2020,
Brian A. McCormick, submitted for
filing, an application for authority to
hold interlocking positions, pursuant to
section 305(b) of the Federal Power Act,
16 U.S.C. 825d(b), Part 45 of the Federal
Energy Regulatory Commission’s Rules
of Practice and Procedure, 18 CFR part
45.8 (2019).
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protest this filing must file in
accordance with Rules 211 and 214 of
the Commission’s Rules of Practice and
Procedure (18 CFR 385.211, 385.214).
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Commission in determining the
appropriate action to be taken, but will
not serve to make protestants parties to
the proceeding. Any person wishing to
become a party must file a notice of
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appropriate. Such notices, motions, or
protests must be filed on or before the
comment date. On or before the
comment date, it is not necessary to
serve motions to intervene or protests
on persons other than the Applicant.
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electronic submission of protests and
interventions in lieu of paper using the
‘‘eFiling’’ link at https://www.ferc.gov.
Persons unable to file electronically
should submit an original and 5 copies
of the protest or intervention to the
Federal Energy Regulatory Commission,
888 First Street NE, Washington, DC
20426.
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(202) 502–8659.
Comment Date: 5:00 p.m. Eastern
Time on March 11, 2020.
Dated: February 20, 2020.
Kimberly D. Bose,
Secretary.
[FR Doc. 2020–03900 Filed 2–26–20; 8:45 am]
BILLING CODE 6717–01–P
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Take notice that the Commission has
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Filed Date: 2/19/20.
Accession Number: 20200219–5124.
Comments Due: 5 p.m. ET 3/2/20.
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clicking on the links or querying the
docket number.
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protest in any of the above proceedings
must file in accordance with Rules 211
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other information, call (866) 208–3676
(toll free). For TTY, call (202) 502–8659.
Dated: February 20, 2020.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2020–03925 Filed 2–26–20; 8:45 am]
BILLING CODE 6717–01–P
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Docket No. RM20–8–000]
Virtualization and Cloud Computing
Services
Federal Energy Regulatory
Commission, Department of Energy.
ACTION: Notice of inquiry.
AGENCY:
The Federal Energy
Regulatory Commission (Commission)
seeks comments regarding the potential
benefits and risks associated with the
use of virtualization and cloud
computing services in association with
bulk electric system operations, as well
as whether barriers exist in the
Commission-approved Critical
Infrastructure Protection Reliability
Standards that impede the voluntary
adoption of virtualization or cloud
computing services.
DATES: Initial Comments are due April
27, 2020, and Reply Comments are due
May 27, 2020.
ADDRESSES: Comments, identified by
docket number, may be filed in the
following ways:
• Electronic Filing through https://
www.ferc.gov. Documents created
electronically using word processing
software should be filed in native
SUMMARY:
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Federal Register / Vol. 85, No. 39 / Thursday, February 27, 2020 / Notices
applications or print-to-PDF format and
not in a scanned format.
• Mail/Hand Delivery: Those unable
to file electronically may mail or handdeliver comments to: Federal Energy
Regulatory Commission, Secretary of the
Commission, 888 First Street NE,
Washington, DC 20426.
• Instructions: For detailed
instructions on submitting comments,
see the Comment Procedures Section of
this document.
FOR FURTHER INFORMATION CONTACT:
Patricia Ephraim Eke, (Technical
Information), Office of Electric
Reliability, Federal Energy Regulatory
Commission, 888 First Street NE,
Washington, DC 20426, (202) 502–
8388, Patricia.Eke@ferc.gov
Kevin Ryan, (Legal Information), Office
of the General Counsel, Federal
Energy Regulatory Commission, 888
First Street NE, Washington, DC
20426, (202) 502–6840, Kevin.Ryan@
ferc.gov.
1. In this
Notice of Inquiry (NOI), the Commission
seeks comments on the potential
benefits and risks associated with the
use of virtualization and cloud
computing services in association with
bulk electric system operations. In
addition, the Commission seeks
comment on whether barriers exist in
the Critical Infrastructure Protection
(CIP) Reliability Standards, which are
developed by the North American
Electric Reliability Corporation (NERC)
and approved by the Commission, that
impede the voluntary adoption of
virtualization or cloud computing
services.
2. This NOI is an outgrowth of
discussions concerning the potential
benefits and risks associated with the
adoption of virtualization and cloud
computing services for bulk electric
system operations at the Commission’s
June 27, 2019 Reliability Technical
Conference and the March 28, 2019
Commission/Department of Energy
(DOE) Security Investments for Energy
Infrastructure Technical Conference.1
3. The Commission intends to use the
record developed in this proceeding to
determine whether it would be
appropriate, pursuant to section
215(d)(5) of the Federal Power Act, to
direct that NERC develop modifications
to the CIP Reliability Standards to
facilitate the voluntary adoption of
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SUPPLEMENTARY INFORMATION:
1 The
records of the June 27, 2019 Reliability
Technical Conference and March 28, 2019
Commission/DOE conference are available on the
Commission’s eLibrary document retrieval system
in Docket Nos. AD19–13–000 and AD19–12–000,
respectively.
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virtualization and cloud computing
services by registered entities.2
Background
A. Virtualization
4. Virtualization is the process of
creating virtual, as opposed to physical,
versions of computer hardware to
minimize the amount of physical
computer hardware resources required
to perform various functions.3
Virtualization is commonly used in
business applications and is managed
through centralized software, referred to
as a hypervisor, that manages multiple
virtual computer resources that can be
used by different processes, customers,
clients, and users. A virtual
environment can be a single program
and the operating system on which it
executes; a combination of multiple
programs and associated operating
systems, networks, computing
environments, storage devices, or other
such digital environments.
5. Virtualization can be used on a
stand-alone basis in a bulk electric
system control center environment to
reduce capital and operating costs,
increase the efficiency of existing
computing assets, and improve incident
recovery, among other reasons.
Virtualization offers the potential for
cost savings in asset management,
including minimizing the need for
physical assets, which require building
space and procuring and maintaining
physical computer hardware. A
virtualized system can also be more
quickly recovered than physical systems
in the event of a malfunction or
compromise.
6. Virtualization is a necessary
technical enabler if the functions of BES
Cyber Systems are to be moved to a
cloud computing environment since a
customer choosing to migrate one or
more on-premise systems to the cloud
will need to virtualize those systems for
use in the cloud.4
B. Cloud Computing
7. The National Institute of Standards
and Technology (NIST) Information
Technology Laboratory Computer
Security Resource Center defines cloud
2 16
U.S.C. 824o(d)(5).
National Institute of Standards and
Technology, Guide to Security for Full
Virtualization Technologies, Special Publication
800–125 (Jan. 2011), https://nvlpubs.nist.gov/
nistpubs/Legacy/SP/nistspecialpublication800125.pdf.
4 BES Cyber System is defined as ‘‘[o]ne or more
BES Cyber Assets logically grouped by a
responsible entity to perform one or more reliability
tasks for a functional entity.’’ Glossary of Terms
Used in NERC Reliability Standards, https://
www.nerc.com/files/glossary_of_terms.pdf. The
acronym BES refers to the bulk electric system.
3 See
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computing as a ‘‘model for enabling
convenient, on-demand network access
to a shared pool of configurable
computing resources (e.g., networks,
servers, storage, applications, and
services) that can be rapidly provisioned
and released with minimal management
effort or service provider interaction.’’ 5
8. The primary cloud service models
include Infrastructure as a Service
(IaaS), Platform as a Service (PaaS), and
Software as a Service (SaaS). These
three cloud service models provide
different levels of flexibility and control
to organizations choosing to use cloud
computing services. Entities may use
cloud computing services for the simple
storage of data or, as discussed above, to
host and operate virtual systems used
for bulk electric system operations. As
a general matter, cloud computing
enables entities to focus resources on
providing core services, such as
transmission or generation of electric
energy, while outsourcing the IT
infrastructure required to support them.
9. Leveraging cloud computing
services in technology and business
processes provides entities the
opportunity to realize benefits in their
IT operations, including greater
scalability, greater flexibility and lower
capital investment. Cloud computing
services provide computing power and
storage at a lower cost than maintaining
in-house IT infrastructure while
providing the capability for almost
instantaneous expansion of services.
Other potential benefits from the
adoption of cloud computing services
include enhanced access to data and
applications due to the inherent
redundancy and multiple pathways
used to access cloud computing
services.
C. Commission Technical Conferences
10. On June 27, 2019, the Commission
held its annual Reliability Technical
Conference to discuss four fundamental
topics, including the impact of cloudbased services and virtualization on
bulk electric system operations,
planning and security.6 The technical
conference addressed, among other
things: (1) Evolution of cloud computing
and virtualization of cloud computing
and virtualization technologies; (2)
outsourcing risk; (3) Reliability
Standards modifications; (4) appropriate
systems for a cloud environment; and
5 NIST, The NIST Definition of Cloud Computing,
Special Publication 800–145 (Sept. 2011), https://
nvlpubs.nist.gov/nistpubs/Legacy/SP/
nistspecialpublication800-145.pdf.
6 FERC, Notice Inviting Post-Technical
Conference Comments, Docket No. AD19–13–000
(Jul. 23, 2019).
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(5) security and non-security related
benefits.
11. In general, panelists at the
Reliability Technical Conference
acknowledged the emergence of
virtualization and cloud computing
services and indicated that the
Commission should take some action to
address the use of these technologies for
bulk electric system data management.
Midcontinent Independent System
Operator (MISO) recommended that the
Commission further engage industry
and cloud service providers in one or
more technical conferences to clarify
issues and direct timely industry action
to establish a way forward with changes
to CIP Reliability Standards specifically
to accommodate the use of cloud
computing services.7 MISO explained
that the benefits of virtualization
include enhanced system recovery. In
particular, MISO noted that during the
past year it was able to recover virtual
assets quicker than traditional
computing assets when testing backup
and recovery processes. American
Public Power Association and Large
Public Power Council, moreover, stated
that if done with care, cloud computing
solutions can reduce risk, increase
flexibility and improve the security
posture of the bulk electric system.8
12. During the Commission/DOE
Security Investments for Energy
Infrastructure Technical Conference on
March 28, 2019, Southwest Power Pool
(SPP) urged more flexibility regarding
the use of cloud computing. SPP stated
that it evaluated a number of products
that would enable it to do a better job
of protecting system data. SPP asserted
the view that the currently-effective CIP
Reliability Standards do not allow
cloud-based technologies despite the
fact that the vast majority of new
products from many of its vendors are
cloud-based. As an example, SPP stated
that it:
believes that it cannot deploy the required
CIP controls for certain system information
were it to be stored on externally-hosted
servers (i.e., ‘‘the cloud’’). Yet, we are finding
that more and more vendors have flagship
products that require all or a portion of CIP
system information to be stored off-premises.
This was a driving factor in our recent
replacement of our service management
software and has also been a complicating
factor in the evaluation of vulnerability
scanning and vulnerability management
solutions. Hence, SPP has given weight to
solutions that are more expensive or do not
provide as much value as some cloud
alternatives. The standards should not be so
prescriptive as to force SPP to avoid industry
7 See
Reliability Technical Conference, Docket
No. AD19–13–000, Tr. 118:6–12 (Rosenthal).
8 Tr. 114:12–14 (Jacobs).
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trends that have proven to be secure, but not
necessarily compliant.9
13. The concerns reflected in the
comments from the two recent technical
conferences have prompted the issuance
of this NOI to seek additional comments
on the benefits and risks associated with
the use of virtualization and cloud
computing services in association with
bulk electric system operations. Further,
to the extent that there are barriers in
the currently-effective CIP Reliability
Standards to their use, the Commission
seeks comment on whether it is
appropriate for the Commission to
direct action to facilitate the voluntary
adoption of virtualization and cloud
computing services.
II. Request for Comments
14. In this proceeding, the
Commission seeks comments on the
potential benefits and risks associated
with the use of virtualization and cloud
computing services, as well as whether
barriers may exist in the CIP Reliability
Standards that impede the adoption of
virtualization or cloud computing.
Specifically, the Commission seeks
comments on four general topics as part
of this inquiry: (A) Scope of potential
use of virtualization and cloud
computing services; (B) potential
benefits and risks associated with
virtualization and cloud computing
services; (C) potential impediments to
adopting virtualization and cloud
computing services; and (D) potential
use of new and emerging technologies
in the current CIP standards framework.
15. In the following sections, we pose
questions that commenters should
address in their submissions. However,
commenters need not address every
topic or answer every question
identified below.
A. Scope of Potential Use of
Virtualization and Cloud Computing
Services
16. As discussed above, virtualization
and cloud computing services offer a
wide variety of potential uses in the
context of users, owners and operators
of the bulk electric system. Some
entities may choose to utilize the cloud
simply for data storage. Other entities
may rely on virtualization and cloud
storage to operate systems that control
one or more core functions. Potential
uses may include one or more of the
BES reliability operating services
described in the Guidelines and
Technical Basis section of Reliability
9 See Nick Brown, Prepared Statement for
Commission/DOE Security Investments for Energy
Infrastructure Technical Conference, Docket No.
AD19–12–000, at 3 (filed Apr. 2, 2019).
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11365
Standard CIP–002–5.1a (Cyber
Security—BES Cyber System
Categorization).10 Specifically, it is
possible that either virtualization or
cloud computing services could be
leveraged for the following reliability
operating services:
D Dynamic Response to BES conditions
D Balancing Load and Generation
D Controlling Frequency (Real Power)
D Controlling Voltage (Reactive Power)
D Managing Constraints
D Monitoring & Control
D Restoration of BES
D Situational Awareness
D Inter-Entity Real-Time Coordination
and Communication
17. Using BES reliability operating
services as a point of reference to
distinguish among possible applications
of virtualization and cloud computing
services in bulk electric system
operations:
A1. Identify and discuss which BES
reliability operating services referenced
above could be implemented in a virtualized
environment.
A2. Identify and discuss which BES
reliability operating services referenced
above could be implemented in a cloud
computing environment.
A3. Identify and discuss any other BES
reliability operating or support services that
could be implemented in a virtualized
environment.
A4. Identify and discuss any other BES
reliability operating, data storage or support
services that could be implemented in a
cloud computing environment.
B. Potential Benefits and Risks
Associated With Virtualization and
Cloud Computing Services
18. The Commission seeks comment
on the potential benefits and risks
associated with virtualization and cloud
computing services:
B1. What are the potential benefits
associated with adopting virtualization for
the BES reliability operating services
identified in response to Questions A1 and
A3?
B2. Are there risks associated with
adopting virtualization for the BES reliability
operating services identified in response to
Questions A1 and A3? If risks exist, discuss
whether these risks can be effectively
mitigated by a responsibility entity.
B3. What are the potential benefits
associated with adopting cloud computing
services for the BES reliability operating
services, data storage and support services
identified in response to Questions A2 and
A4?
B4. Are there risks associated with
adopting cloud computing services for the
BES reliability operating services data storage
10 See Reliability Standard CIP–002–5.1a (Cyber
Security—BES Cyber System Categorization),
Guidelines and Technical Basis at 17–18.
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and support services identified in response to
Questions A2 and A4? If risks exist, discuss
whether these risks can be effectively
mitigated by a responsible entity.
B5. What are the potential benefits of
relying on third-party assessments to ensure
the secure use of virtualization and cloud
computing services for BES reliability
operations and support services?
B6. Discuss any risks associated with
relying on third party assessments to ensure
the secure use of virtualization and cloud
computing services for BES reliability
operations and support services and potential
solutions to mitigate those risks.
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C. Potential Impediments to Adopting
Virtualization and Cloud Computing
Services
19. As discussed above, during the
Commission’s 2019 annual Reliability
Technical Conference, several
commenters alluded to the fact that
cloud-based offerings continue to
increase as vendors are moving more of
their services to the cloud.11
Commenters further asserted that there
is uncertainty on how virtualization and
cloud computing services can be
leveraged within the existing CIP
framework. Similarly, at the March 2019
Commission/DOE Security Investments
for Energy Infrastructure Technical
Conference, a panelist asserted that
there is uncertainty among registered
entities on whether the CIP Reliability
Standards allow cloud-based
technologies ‘‘despite the fact that the
majority of new products from many
vendors are cloud-based.’’ 12
20. In light of the concerns expressed
at these technical conferences, the
Commission seeks comment on
potential challenges with how the
implementation of virtualization and
cloud computing technologies will fit
into the framework of the CIP Reliability
Standards, and possible solutions to
those challenges:
C1. Provide comment on the validity of the
panelists’ concern discussed above and
discuss the extent to which the trend toward
cloud-based services could affect reliable and
secure bulk electric system operations.
C2. Are there any technical challenges in
implementing virtualization technology for
the BES reliability operating services
identified in response to Question A1 that
result from the current CIP Reliability
Standards? Discuss how the CIP Reliability
Standards could be augmented to address
these challenges.
C3. Are there any challenges in
implementing virtualization technology for
the BES reliability operating services
identified in response to Question A1 that
11 See June 27, 2019 annual Reliability Technical
Conference, Transcript pages 113 and 115–116.
12 See March 28, 2019, Commission/DOE Security
Investments for Energy Infrastructure Technical
Conference, Transcript page 128.
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result from compliance obligations associated
with the CIP Reliability Standards? Discuss
how the CIP Reliability Standards could be
augmented to address these challenges.
C4. Are there any technical challenges in
implementing cloud computing technology
for the BES reliability operating services
identified in response to Question A2 that
result from the current CIP Reliability
Standards? Discuss how the CIP Reliability
Standards could be augmented to address
these challenges.
C5. Are there any challenges in
implementing cloud computing technology
for the BES reliability operating services
identified in response to Question A2 that
result from compliance obligations associated
with the CIP Reliability Standards? Discuss
how the CIP Reliability Standards could be
augmented to address these challenges.
D. Potential Use of New and Emerging
Technologies in the Current CIP
Standards Framework
21. The Commission seeks comment
on potential new and emerging
technologies beyond virtualization and
cloud computing that responsible
entities may be interested in adopting
for the BES reliability operating services
and if the CIP Reliability Standards
would allow these technologies to be
adopted.
D1. In addition to virtualization and
clouding computing, discuss whether the CIP
Reliability Standards limit the ability to take
full advantage of new and emerging
technologies for BES reliability operating
services. Explain the types of new
technologies, the potential benefits and how
the CIP Reliability Standards may limit their
use.
III. Comment Procedures
22. The Commission invites interested
persons to submit comments on the
matters and issues proposed in this
notice, including any related matters or
alternative proposals that commenters
may wish to discuss. Comments are due
April 27, 2020, and Reply Comments are
due May 27, 2020. Comments must refer
to Docket No. RM20–8–000, and must
include the commenter’s name, the
organization they represent, if
applicable, and their address.
23. The Commission encourages
comments to be filed electronically via
the eFiling link on the Commission’s
website at https://www.ferc.gov. The
Commission accepts most standard
word-processing formats. Documents
created electronically using wordprocessing software should be filed in
native applications or print-to-PDF
format and not in a scanned format.
Commenters filing electronically do not
need to make a paper filing.
24. Commenters that are not able to
file comments electronically must send
an original of their comments to:
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Federal Energy Regulatory Commission,
Secretary of the Commission, 888 First
Street NE, Washington, DC 20426.
25. All comments will be placed in
the Commission’s public files and may
be viewed, printed, or downloaded
remotely as described in the Document
Availability section below. Commenters
on this proposal are not required to
serve copies of their comments on other
commenters.
IV. Document Availability
26. In addition to publishing the full
text of this document in the Federal
Register, the Commission provides all
interested persons an opportunity to
view and/or print the contents of this
document via the internet through the
Commission’s Home Page (https://
www.ferc.gov) and in the Commission’s
Public Reference Room during normal
business hours (8:30 a.m. to 5:00 p.m.
eastern time) at 888 First Street NE,
Room 2A, Washington, DC 20426.
27. From the Commission’s Home
Page on the internet, this information is
available on eLibrary. The full text of
this document is available on eLibrary
in PDF and Microsoft Word format for
viewing, printing, and/or downloading.
To access this document in eLibrary,
type the docket number excluding the
last three digits of this document in the
docket number field.
28. User assistance is available for
eLibrary and the Commission’s website
during normal business hours from the
Commission’s Online Support at (202)
502–6652 (toll free at 1–866–208–3676)
or email at ferconlinesupport@ferc.gov,
or the Public Reference Room at (202)
502–8371, TTY (202) 502–8659. Email
the Public Reference Room at
public.referenceroom@ferc.gov.
By direction of the Commission.
Issued: February 20, 2020.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2020–03928 Filed 2–26–20; 8:45 am]
BILLING CODE 6717–01–P
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Project No. 3273–024]
Chittenden Falls Hydropower, Inc.;
Notice of Application Ready for
Environmental Analysis and Soliciting
Comments, Recommendations, Terms
and Conditions, and Prescriptions
Take notice that the following
hydroelectric application has been filed
with the Commission and is available
for public inspection.
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Agencies
[Federal Register Volume 85, Number 39 (Thursday, February 27, 2020)]
[Notices]
[Pages 11363-11366]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-03928]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket No. RM20-8-000]
Virtualization and Cloud Computing Services
AGENCY: Federal Energy Regulatory Commission, Department of Energy.
ACTION: Notice of inquiry.
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SUMMARY: The Federal Energy Regulatory Commission (Commission) seeks
comments regarding the potential benefits and risks associated with the
use of virtualization and cloud computing services in association with
bulk electric system operations, as well as whether barriers exist in
the Commission-approved Critical Infrastructure Protection Reliability
Standards that impede the voluntary adoption of virtualization or cloud
computing services.
DATES: Initial Comments are due April 27, 2020, and Reply Comments are
due May 27, 2020.
ADDRESSES: Comments, identified by docket number, may be filed in the
following ways:
Electronic Filing through https://www.ferc.gov. Documents
created electronically using word processing software should be filed
in native
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applications or print-to-PDF format and not in a scanned format.
Mail/Hand Delivery: Those unable to file electronically
may mail or hand-deliver comments to: Federal Energy Regulatory
Commission, Secretary of the Commission, 888 First Street NE,
Washington, DC 20426.
Instructions: For detailed instructions on submitting
comments, see the Comment Procedures Section of this document.
FOR FURTHER INFORMATION CONTACT:
Patricia Ephraim Eke, (Technical Information), Office of Electric
Reliability, Federal Energy Regulatory Commission, 888 First Street NE,
Washington, DC 20426, (202) 502-8388, [email protected]
Kevin Ryan, (Legal Information), Office of the General Counsel, Federal
Energy Regulatory Commission, 888 First Street NE, Washington, DC
20426, (202) 502-6840, [email protected].
SUPPLEMENTARY INFORMATION: 1. In this Notice of Inquiry (NOI), the
Commission seeks comments on the potential benefits and risks
associated with the use of virtualization and cloud computing services
in association with bulk electric system operations. In addition, the
Commission seeks comment on whether barriers exist in the Critical
Infrastructure Protection (CIP) Reliability Standards, which are
developed by the North American Electric Reliability Corporation (NERC)
and approved by the Commission, that impede the voluntary adoption of
virtualization or cloud computing services.
2. This NOI is an outgrowth of discussions concerning the potential
benefits and risks associated with the adoption of virtualization and
cloud computing services for bulk electric system operations at the
Commission's June 27, 2019 Reliability Technical Conference and the
March 28, 2019 Commission/Department of Energy (DOE) Security
Investments for Energy Infrastructure Technical Conference.\1\
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\1\ The records of the June 27, 2019 Reliability Technical
Conference and March 28, 2019 Commission/DOE conference are
available on the Commission's eLibrary document retrieval system in
Docket Nos. AD19-13-000 and AD19-12-000, respectively.
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3. The Commission intends to use the record developed in this
proceeding to determine whether it would be appropriate, pursuant to
section 215(d)(5) of the Federal Power Act, to direct that NERC develop
modifications to the CIP Reliability Standards to facilitate the
voluntary adoption of virtualization and cloud computing services by
registered entities.\2\
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\2\ 16 U.S.C. 824o(d)(5).
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Background
A. Virtualization
4. Virtualization is the process of creating virtual, as opposed to
physical, versions of computer hardware to minimize the amount of
physical computer hardware resources required to perform various
functions.\3\ Virtualization is commonly used in business applications
and is managed through centralized software, referred to as a
hypervisor, that manages multiple virtual computer resources that can
be used by different processes, customers, clients, and users. A
virtual environment can be a single program and the operating system on
which it executes; a combination of multiple programs and associated
operating systems, networks, computing environments, storage devices,
or other such digital environments.
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\3\ See National Institute of Standards and Technology, Guide to
Security for Full Virtualization Technologies, Special Publication
800-125 (Jan. 2011), https://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-125.pdf.
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5. Virtualization can be used on a stand-alone basis in a bulk
electric system control center environment to reduce capital and
operating costs, increase the efficiency of existing computing assets,
and improve incident recovery, among other reasons. Virtualization
offers the potential for cost savings in asset management, including
minimizing the need for physical assets, which require building space
and procuring and maintaining physical computer hardware. A virtualized
system can also be more quickly recovered than physical systems in the
event of a malfunction or compromise.
6. Virtualization is a necessary technical enabler if the functions
of BES Cyber Systems are to be moved to a cloud computing environment
since a customer choosing to migrate one or more on-premise systems to
the cloud will need to virtualize those systems for use in the
cloud.\4\
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\4\ BES Cyber System is defined as ``[o]ne or more BES Cyber
Assets logically grouped by a responsible entity to perform one or
more reliability tasks for a functional entity.'' Glossary of Terms
Used in NERC Reliability Standards, https://www.nerc.com/files/glossary_of_terms.pdf. The acronym BES refers to the bulk electric
system.
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B. Cloud Computing
7. The National Institute of Standards and Technology (NIST)
Information Technology Laboratory Computer Security Resource Center
defines cloud computing as a ``model for enabling convenient, on-demand
network access to a shared pool of configurable computing resources
(e.g., networks, servers, storage, applications, and services) that can
be rapidly provisioned and released with minimal management effort or
service provider interaction.'' \5\
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\5\ NIST, The NIST Definition of Cloud Computing, Special
Publication 800-145 (Sept. 2011), https://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-145.pdf.
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8. The primary cloud service models include Infrastructure as a
Service (IaaS), Platform as a Service (PaaS), and Software as a Service
(SaaS). These three cloud service models provide different levels of
flexibility and control to organizations choosing to use cloud
computing services. Entities may use cloud computing services for the
simple storage of data or, as discussed above, to host and operate
virtual systems used for bulk electric system operations. As a general
matter, cloud computing enables entities to focus resources on
providing core services, such as transmission or generation of electric
energy, while outsourcing the IT infrastructure required to support
them.
9. Leveraging cloud computing services in technology and business
processes provides entities the opportunity to realize benefits in
their IT operations, including greater scalability, greater flexibility
and lower capital investment. Cloud computing services provide
computing power and storage at a lower cost than maintaining in-house
IT infrastructure while providing the capability for almost
instantaneous expansion of services. Other potential benefits from the
adoption of cloud computing services include enhanced access to data
and applications due to the inherent redundancy and multiple pathways
used to access cloud computing services.
C. Commission Technical Conferences
10. On June 27, 2019, the Commission held its annual Reliability
Technical Conference to discuss four fundamental topics, including the
impact of cloud-based services and virtualization on bulk electric
system operations, planning and security.\6\ The technical conference
addressed, among other things: (1) Evolution of cloud computing and
virtualization of cloud computing and virtualization technologies; (2)
outsourcing risk; (3) Reliability Standards modifications; (4)
appropriate systems for a cloud environment; and
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(5) security and non-security related benefits.
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\6\ FERC, Notice Inviting Post-Technical Conference Comments,
Docket No. AD19-13-000 (Jul. 23, 2019).
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11. In general, panelists at the Reliability Technical Conference
acknowledged the emergence of virtualization and cloud computing
services and indicated that the Commission should take some action to
address the use of these technologies for bulk electric system data
management. Midcontinent Independent System Operator (MISO) recommended
that the Commission further engage industry and cloud service providers
in one or more technical conferences to clarify issues and direct
timely industry action to establish a way forward with changes to CIP
Reliability Standards specifically to accommodate the use of cloud
computing services.\7\ MISO explained that the benefits of
virtualization include enhanced system recovery. In particular, MISO
noted that during the past year it was able to recover virtual assets
quicker than traditional computing assets when testing backup and
recovery processes. American Public Power Association and Large Public
Power Council, moreover, stated that if done with care, cloud computing
solutions can reduce risk, increase flexibility and improve the
security posture of the bulk electric system.\8\
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\7\ See Reliability Technical Conference, Docket No. AD19-13-
000, Tr. 118:6-12 (Rosenthal).
\8\ Tr. 114:12-14 (Jacobs).
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12. During the Commission/DOE Security Investments for Energy
Infrastructure Technical Conference on March 28, 2019, Southwest Power
Pool (SPP) urged more flexibility regarding the use of cloud computing.
SPP stated that it evaluated a number of products that would enable it
to do a better job of protecting system data. SPP asserted the view
that the currently-effective CIP Reliability Standards do not allow
cloud-based technologies despite the fact that the vast majority of new
products from many of its vendors are cloud-based. As an example, SPP
stated that it:
believes that it cannot deploy the required CIP controls for certain
system information were it to be stored on externally-hosted servers
(i.e., ``the cloud''). Yet, we are finding that more and more
vendors have flagship products that require all or a portion of CIP
system information to be stored off-premises. This was a driving
factor in our recent replacement of our service management software
and has also been a complicating factor in the evaluation of
vulnerability scanning and vulnerability management solutions.
Hence, SPP has given weight to solutions that are more expensive or
do not provide as much value as some cloud alternatives. The
standards should not be so prescriptive as to force SPP to avoid
industry trends that have proven to be secure, but not necessarily
compliant.\9\
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\9\ See Nick Brown, Prepared Statement for Commission/DOE
Security Investments for Energy Infrastructure Technical Conference,
Docket No. AD19-12-000, at 3 (filed Apr. 2, 2019).
13. The concerns reflected in the comments from the two recent
technical conferences have prompted the issuance of this NOI to seek
additional comments on the benefits and risks associated with the use
of virtualization and cloud computing services in association with bulk
electric system operations. Further, to the extent that there are
barriers in the currently-effective CIP Reliability Standards to their
use, the Commission seeks comment on whether it is appropriate for the
Commission to direct action to facilitate the voluntary adoption of
virtualization and cloud computing services.
II. Request for Comments
14. In this proceeding, the Commission seeks comments on the
potential benefits and risks associated with the use of virtualization
and cloud computing services, as well as whether barriers may exist in
the CIP Reliability Standards that impede the adoption of
virtualization or cloud computing. Specifically, the Commission seeks
comments on four general topics as part of this inquiry: (A) Scope of
potential use of virtualization and cloud computing services; (B)
potential benefits and risks associated with virtualization and cloud
computing services; (C) potential impediments to adopting
virtualization and cloud computing services; and (D) potential use of
new and emerging technologies in the current CIP standards framework.
15. In the following sections, we pose questions that commenters
should address in their submissions. However, commenters need not
address every topic or answer every question identified below.
A. Scope of Potential Use of Virtualization and Cloud Computing
Services
16. As discussed above, virtualization and cloud computing services
offer a wide variety of potential uses in the context of users, owners
and operators of the bulk electric system. Some entities may choose to
utilize the cloud simply for data storage. Other entities may rely on
virtualization and cloud storage to operate systems that control one or
more core functions. Potential uses may include one or more of the BES
reliability operating services described in the Guidelines and
Technical Basis section of Reliability Standard CIP-002-5.1a (Cyber
Security--BES Cyber System Categorization).\10\ Specifically, it is
possible that either virtualization or cloud computing services could
be leveraged for the following reliability operating services:
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\10\ See Reliability Standard CIP-002-5.1a (Cyber Security--BES
Cyber System Categorization), Guidelines and Technical Basis at 17-
18.
[ssquf] Dynamic Response to BES conditions
[ssquf] Balancing Load and Generation
[ssquf] Controlling Frequency (Real Power)
[ssquf] Controlling Voltage (Reactive Power)
[ssquf] Managing Constraints
[ssquf] Monitoring & Control
[ssquf] Restoration of BES
[ssquf] Situational Awareness
[ssquf] Inter-Entity Real-Time Coordination and Communication
17. Using BES reliability operating services as a point of
reference to distinguish among possible applications of virtualization
and cloud computing services in bulk electric system operations:
A1. Identify and discuss which BES reliability operating
services referenced above could be implemented in a virtualized
environment.
A2. Identify and discuss which BES reliability operating
services referenced above could be implemented in a cloud computing
environment.
A3. Identify and discuss any other BES reliability operating or
support services that could be implemented in a virtualized
environment.
A4. Identify and discuss any other BES reliability operating,
data storage or support services that could be implemented in a
cloud computing environment.
B. Potential Benefits and Risks Associated With Virtualization and
Cloud Computing Services
18. The Commission seeks comment on the potential benefits and
risks associated with virtualization and cloud computing services:
B1. What are the potential benefits associated with adopting
virtualization for the BES reliability operating services identified
in response to Questions A1 and A3?
B2. Are there risks associated with adopting virtualization for
the BES reliability operating services identified in response to
Questions A1 and A3? If risks exist, discuss whether these risks can
be effectively mitigated by a responsibility entity.
B3. What are the potential benefits associated with adopting
cloud computing services for the BES reliability operating services,
data storage and support services identified in response to
Questions A2 and A4?
B4. Are there risks associated with adopting cloud computing
services for the BES reliability operating services data storage
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and support services identified in response to Questions A2 and A4?
If risks exist, discuss whether these risks can be effectively
mitigated by a responsible entity.
B5. What are the potential benefits of relying on third-party
assessments to ensure the secure use of virtualization and cloud
computing services for BES reliability operations and support
services?
B6. Discuss any risks associated with relying on third party
assessments to ensure the secure use of virtualization and cloud
computing services for BES reliability operations and support
services and potential solutions to mitigate those risks.
C. Potential Impediments to Adopting Virtualization and Cloud Computing
Services
19. As discussed above, during the Commission's 2019 annual
Reliability Technical Conference, several commenters alluded to the
fact that cloud-based offerings continue to increase as vendors are
moving more of their services to the cloud.\11\ Commenters further
asserted that there is uncertainty on how virtualization and cloud
computing services can be leveraged within the existing CIP framework.
Similarly, at the March 2019 Commission/DOE Security Investments for
Energy Infrastructure Technical Conference, a panelist asserted that
there is uncertainty among registered entities on whether the CIP
Reliability Standards allow cloud-based technologies ``despite the fact
that the majority of new products from many vendors are cloud-based.''
\12\
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\11\ See June 27, 2019 annual Reliability Technical Conference,
Transcript pages 113 and 115-116.
\12\ See March 28, 2019, Commission/DOE Security Investments for
Energy Infrastructure Technical Conference, Transcript page 128.
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20. In light of the concerns expressed at these technical
conferences, the Commission seeks comment on potential challenges with
how the implementation of virtualization and cloud computing
technologies will fit into the framework of the CIP Reliability
Standards, and possible solutions to those challenges:
C1. Provide comment on the validity of the panelists' concern
discussed above and discuss the extent to which the trend toward
cloud-based services could affect reliable and secure bulk electric
system operations.
C2. Are there any technical challenges in implementing
virtualization technology for the BES reliability operating services
identified in response to Question A1 that result from the current
CIP Reliability Standards? Discuss how the CIP Reliability Standards
could be augmented to address these challenges.
C3. Are there any challenges in implementing virtualization
technology for the BES reliability operating services identified in
response to Question A1 that result from compliance obligations
associated with the CIP Reliability Standards? Discuss how the CIP
Reliability Standards could be augmented to address these
challenges.
C4. Are there any technical challenges in implementing cloud
computing technology for the BES reliability operating services
identified in response to Question A2 that result from the current
CIP Reliability Standards? Discuss how the CIP Reliability Standards
could be augmented to address these challenges.
C5. Are there any challenges in implementing cloud computing
technology for the BES reliability operating services identified in
response to Question A2 that result from compliance obligations
associated with the CIP Reliability Standards? Discuss how the CIP
Reliability Standards could be augmented to address these
challenges.
D. Potential Use of New and Emerging Technologies in the Current CIP
Standards Framework
21. The Commission seeks comment on potential new and emerging
technologies beyond virtualization and cloud computing that responsible
entities may be interested in adopting for the BES reliability
operating services and if the CIP Reliability Standards would allow
these technologies to be adopted.
D1. In addition to virtualization and clouding computing,
discuss whether the CIP Reliability Standards limit the ability to
take full advantage of new and emerging technologies for BES
reliability operating services. Explain the types of new
technologies, the potential benefits and how the CIP Reliability
Standards may limit their use.
III. Comment Procedures
22. The Commission invites interested persons to submit comments on
the matters and issues proposed in this notice, including any related
matters or alternative proposals that commenters may wish to discuss.
Comments are due April 27, 2020, and Reply Comments are due May 27,
2020. Comments must refer to Docket No. RM20-8-000, and must include
the commenter's name, the organization they represent, if applicable,
and their address.
23. The Commission encourages comments to be filed electronically
via the eFiling link on the Commission's website at https://www.ferc.gov. The Commission accepts most standard word-processing
formats. Documents created electronically using word-processing
software should be filed in native applications or print-to-PDF format
and not in a scanned format. Commenters filing electronically do not
need to make a paper filing.
24. Commenters that are not able to file comments electronically
must send an original of their comments to: Federal Energy Regulatory
Commission, Secretary of the Commission, 888 First Street NE,
Washington, DC 20426.
25. All comments will be placed in the Commission's public files
and may be viewed, printed, or downloaded remotely as described in the
Document Availability section below. Commenters on this proposal are
not required to serve copies of their comments on other commenters.
IV. Document Availability
26. In addition to publishing the full text of this document in the
Federal Register, the Commission provides all interested persons an
opportunity to view and/or print the contents of this document via the
internet through the Commission's Home Page (https://www.ferc.gov) and
in the Commission's Public Reference Room during normal business hours
(8:30 a.m. to 5:00 p.m. eastern time) at 888 First Street NE, Room 2A,
Washington, DC 20426.
27. From the Commission's Home Page on the internet, this
information is available on eLibrary. The full text of this document is
available on eLibrary in PDF and Microsoft Word format for viewing,
printing, and/or downloading. To access this document in eLibrary, type
the docket number excluding the last three digits of this document in
the docket number field.
28. User assistance is available for eLibrary and the Commission's
website during normal business hours from the Commission's Online
Support at (202) 502-6652 (toll free at 1-866-208-3676) or email at
[email protected], or the Public Reference Room at (202) 502-
8371, TTY (202) 502-8659. Email the Public Reference Room at
[email protected].
By direction of the Commission.
Issued: February 20, 2020.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2020-03928 Filed 2-26-20; 8:45 am]
BILLING CODE 6717-01-P