Infrastructure Briefing — October 28, 2024

Executive briefing: On October 4, 2024 the North American Electric Reliability Corporation (NERC) petitioned FERC to approve Reliability Standard CIP-014-3, expanding physical security risk assessments, verified mitigation plans, and supply-chain attestations for bulk electric system transmission stations. Three weeks later, the European Union Agency for the Cooperation of Energy Regulators (ACER) issued Recommendation 05/2024 urging national regulators to enforce the Critical Entities Resilience (CER) Regulation with harmonised threat intelligence sharing, supplier due diligence, and recovery metrics. Operators now face matching evidence demands on both sides of the Atlantic.

Key industry signals

Expand critical station identification. CIP-014-3 requires using updated transmission planning studies, threat intelligence, and adversary capability modelling to identify substations whose loss could cause cascading outages; ACER’s Recommendation 05/2024 expects CER operators to perform similar impact analyses across cross-border corridors.
Harden physical protections and redundancy. NERC’s filing adds requirements for independent reviews of mitigation plans including ballistic protection, intrusion detection, and alternate control centres, while ACER calls for redundant energy routes and mutual assistance protocols validated through regional exercises.
Close supply-chain and contractor gaps. Both regulators highlight third-party exposures: CIP-014-3 references coordination with CIP-013 supply-chain controls, and ACER directs national authorities to test supplier resilience, secure maintenance access, and cyber-physical monitoring contracts.

Control alignment

NERC CIP-014-3 & CIP-013-3. Document physical security plans, inspection cadences, and vendor vetting artefacts for bulk electric system (BES) cyber assets, ensuring evidence cross-references CIP-013-3 procurement and change management controls.
EU CER Regulation (Regulation (EU) 2022/2557). Map ACER’s expectations to corporate resilience frameworks, capturing governance bodies, risk registers, and reporting lines mandated for critical entities.
ISO/IEC 27019:2017. Align electric utility OT security requirements with CIP-014-3 perimeter safeguards and ACER’s resilience scenario testing to deliver a unified compliance package.

Detection and response priorities

Implement converged telemetry that fuses substation access control, video analytics, and grid state estimators so anomalous activity triggers CIP-014-3 incident response thresholds and CER notification timelines.
Feed supplier risk indicators, maintenance schedules, and intrusion alarms into SOC dashboards to meet ACER’s supply-chain supervision guidance and NERC’s independent review requirements.
Exercise joint drills with transmission operators, national TSOs, and law enforcement simulating coordinated attacks or sabotage, ensuring logs and after-action reports satisfy both regulators’ audit expectations.

Enablement moves

Brief boards and regulators on dual compliance milestones—FERC review timelines for CIP-014-3 and Member State adoption plans for the CER Regulation—highlighting investment needs and evidence readiness.
Update supplier contracts with resilience key performance indicators (KPIs), requiring disclosure of hardening measures, remote access safeguards, and recovery SLAs that align with CIP-013-3 and ACER’s Recommendation 05/2024.
Fund intelligence sharing and digital twins that stress-test transmission topology, ensuring cross-border contingency plans demonstrate the credibility weighting regulators expect.

Sources

Zeph Tech fortifies cross-regional infrastructure programmes with CIP-014-3 physical security engineering, CER governance playbooks, and supplier resilience scoring.