Tom Alrich's Blog, too

Tom Alrich's Blog, too

What can the "Cloud CIP" drafting team learn from the CIP-013 experience?

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Tom Alrich
Aug 11, 2025
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Note from Tom: Starting August 11, my new posts in Substack will only be available to paid subscribers, although I will occasionally put up a free post; I will also stop putting up new posts on Blogspot, also with occasional exceptions. To have uninterrupted access to my new posts, please open a paid subscription on Substack or upgrade your free subscription to a paid one. However, everyone with a free or paid account can access my blog’s free chat.

A paid subscription to this blog costs $30 per year or $5 per month; anyone who can’t pay that should email me, since I don’t want anyone not to be able to read my posts if they are unable to pay for them. If you would like to be recognized as one of the founding members of this blog, you can subscribe as a Founder for $100 per year (although you can give more if you are so inclined. It will be appreciated!). Please consider doing that.

I hope you understand my reason for making this change: I put in a lot of time on the blog, but I can’t continue to do that without some compensation for my time. This seems like the best and least intrusive way to do it.

I’ve said multiple times that the “Cloud CIP” standards, that will make full use of the cloud “legal” for NERC entities with high and medium impact CIP environments, are unlikely to be fully drafted, approved and implemented before 2031; frankly, I think even that date is optimistic, absent some extraordinary action by the NERC Board of Trustees.

However, I think timing is only the second biggest concern about the Cloud CIP standards. The biggest concern is whether the drafting of the standards will be hurried so much that they won’t do much good once they’re implemented. I have attended (and participated in) the meetings of multiple CIP Standards Drafting Teams (SDTs) previously, so I’ve had a chance to observe how they work. The biggest disappointment I’ve had was with CIP-013-1, although as you will see, I don’t blame the team that drafted it for its problems.

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