The Top Level Disconnect

The first Smart Grid Cyber Security Summit has come and gone, and was much more successful than I ever imagined it would be (especially for being the first of its kind). Being the conference chairman, I was thrilled at all the attendees who took the time to come up to me during networking breaks and thank me for holding the conference, and consistently asking me "When are you holding the next one." I was amazed at the attendees who traveled from Europe and Asia, and all the government defense contractors, AMI vendor security specialists, utility representatives, consultants, members of the media, and FERC Commissioner Moeller...all who came to take part in what many felt was a fantastic opportunity for stakeholders at many levels of the Smart Grid security ecosystem.

What struck me as interesting, however, was a point that was raised by Dr. Fred Cohen, who delivered the keynote address on the 2nd day of the conference. His presentation focused on the lack of (and need for) security expertise in the ever expanding cyber world, and some proposed solutions (which included a bit of self promotion, since Dr. Cohen is currently operating a school specializing in security related academics). Something he said struck a chord in me, and while I have been aware of the situation for quite some time, I have been pondering it quite a bit the last several days. What Dr. Cohen did was posed a question to the audience, asking how many attendees were CEO's (or top level executives) of either AMI vendor organizations or utilities. Nobody raised their hand (and, in fact, nobody at that level signed up to attend the conference), and Dr. Cohen proceeded to point out that until management at that level takes an active role in dealing with security, we will continue to witness a shortfall in security.

Okay, in all fairness this was the first Smart Grid Cyber Security Summit, and CEO's are busy people, and who the heck am I anyhow? Yet his point still rings true in the security world.

The fact is that CEO's simply do not participate in the cyber security ecosystem at any appreciable level, and that leads to the obvious question "Why should they?"

In a word...MONEY!

A CEO's job, after all, is to make sure the organization's income level goes up and the amount of money leaving the company does not go up faster than what is coming in. That is the essence of what being a successful CEO is all about. If the company is publicly traded, then it is all about keeping the stock price from falling. No matter what anyone tells you, that is the name of the game, and always has been, and always will be.

So that brings us back to security. One of the most difficult expenditures to justify to a CEO is the cost of security. Trying to demonstrate a return on investment for security is next to impossible. Security is simply not considered a feature a customer is willing to pay for. Rather, it is something that customers expect to be part of "the package". Customers of AMI vendors, for example, want a decent meter at a low price that also happens to be secure because there are enough people "out there" making enough noise about Smart Grid security to get their attention. This noise includes the government, bloggers, the media, security "hobbyists", security professionals, and privacy proponents...to name just a few. While this may be enough to get the attention of decision makers, it is generally not enough to get decision makers to dedicate any more resources than necessary to divert the attention from their organizations to someone else's. If a top level decision maker believes the attention is (or may) negatively impact the bottom line, more resources are generally expended. Now I have to say that I may be painting the corporate world with a very broad brush, and I am sure that there are some high level executives that want to do the right thing because it is the right thing to do, but their ultimate survival depends on keeping the company cash flow positive and profitable. Stockholders simply do not reward any other behavior.

...and security can be very expensive. It is especially expensive if it is poorly done, and really amounts to a waste of time and money in such cases. If it is not part of the design, it can mean lost revenues due to customers going to a competitor, or it can amount to outright devastating losses in the event of a serious malicious attack. Imagine an AMI vendor that installs 20 million meters and it is later determined that the meters are vulnerable to a very serious security related threat that requires an outright replacement of meters. I am not talking about something theoretical, but rather a vulnerability that turns into a real world exploit. An attacker does not need to, for example, shut down power to millions of people in order for the exploit to prove effective. A few thousand is plenty (maybe even less). It does not take a massive failure of all systems to negatively impact the reputation (and market cap) of a company.

Just look at what happened to both Toyota and BP. It only took a few failures for Toyota to lose billions in market cap, and 1 major failure for BP to lose so much market cap that it dramatically impacted the retirement accounts of millions of British citizens. If a major publicly traded utility should become the victim of such unfortunate circumstances, what potential economic impact could this translate to? The answer is really a big unknown.

It seems prudent, at this point, for CEO's (and other top level executives) of organizations involved in the Smart Grid to become a bit more involved in actively participating in the world of Smart Grid security. One utility representative at the conference mentioned that the high level executives literally pour money into security when they discover that they are about to be audited by NERC, but other times are not so willing to open the coffers. This really does not make sense, and is not indicative of due diligence. If high level executives had a better understanding of the ecosystem, and the concerns of stakeholders, and the dynamic environment surrounding Smart Grid security, then they could make better and more informed decisions on where and how to dedicate resources. It comes down to being proactive rather than reactive.

I am planning to hold another Smart Grid Cyber Security Summit in the near future. I will make sure to reach out to the CEO's of utilities, AMI vendors, and other stakeholder organizations involved in building the Smart Grid. I am hoping they will view this as an opportunity to become part of the solution.

...because otherwise they may indeed be part of the problem.

The Importance of Trusted Relationships

As a security professional, I have had the opportunity to work with many different companies in the ever expanding world of security. Some of these companies have been very large (multi-billion dollar companies), and other have been quite small. The larger companies have the dubious distinction of being able to pour enormous amounts of marketing dollars into convincing the world that they are at the leading edge with respect to security. Unfortunately, this is absolutely no indicator whatsoever of the security posture of a company. In fact, as I have discovered on more than one occasion, some companies will opt to spend enormous amounts of money on everything EXCEPT building better security, hoping to convince their potential customers that they are the right choice to go with.

I think it is no big secret that many corporations seem to have no problem "embellishing" when it comes to the information they choose to share with the world. We have all seen enough of this at this point in our lives to know it is "just the way it is" in the world of business. We simply accept the fact that some companies choose to create their own versions of reality, and make choices to do business with them despite what we may believe about them. For example, we may not believe that an oil company is as committed to safety or environmental soundness as their public relations department may say they are, but we still choose to buy their petroleum products.

The fact is, most of us are not overly concerned about an oil company's safety record or what they are doing to make our environment better when we purchase fuel. If an company does not have a good safety record or destroys our environment we simply do not make the connection between that and our lives when we are at the fuel pump. We have other things on our minds.

With other products, it is perhaps a bit different. If a company that produces food or drugs is found to be acting in a scandalous manner, we tend to become a bit more nervous (perhaps more with drugs than food). Finding out that a drug company is being run by a bunch of corrupt and non-trustworthy people may indeed be cause for concern (at least it would be with me). At a more granular level, finding out that my personal physician is seedy lowlife would certainly make me ask my HMO to provide me with a new doctor. The fact is that when we are forced to trust our lives to a company or person, we want to make sure we are dealing with PEOPLE who can be counted on.

You see, dear reader, an organization is portrayed as being an entity (i.e. a corporation), but we all know that the organization is ultimately a collection of people. Despite the attempt by such organizations to make it about the entity, it is always the people who make or break it.

This certainly holds true in the world of security. When it comes to security products (i.e. security hardware), there are many companies to choose from. In fact, most of the security hardware available today (such as security chips) have become a commodity. When I speak to vendors of AMI (Smart Grid) products, or to organizations interested in implementing security products in health care organizations, one of the first questions that comes up is "How stable and reliable is the company making the security products?".

Organization who are making decisions about security products are transitioning from those who simply wanted to look like they were doing something to ones who are expending resources on products and services that do what they are supposed to do. This is largely driven by the nearly insatiable appetite the hacking community seems to have for breaking down security systems. When I present a security product line to a company, they ask a lot of questions. This is a welcome departure from several years back, when a company simply asked us what they could buy that fit within a given budget. Today, they want to be sure they are making the right decision for the long haul.

What I have found is that is seems to be very important that the organizations making security decisions trust the organizations they do business with at a much deeper level than ever before. I have intimate one-on-one discussions with security professionals and decision makers in companies who literally want my opinion of the companies I represent. They ask questions like "Do you think these guys are going to be around a while?" and "Are they trustworthy?" and "How do you find them compared to Company B?".

While remaining as tactful as I can, I always tell the truth, because these days most people I speak to in the security world VERIFY what I tell them. I know this because on more than one occasion I have had them return to me and say "I checked out what you said, and found out it was true." At first, I was taken aback by this (at least momentarily), but now I find it absolutely refreshing. In fact, sometimes I take the time to send citations for the claims I make, in order to make it easier for them to verify what I tell them.

You see, ultimately security is built on trust. The character of the people who make up an organization is as important (if not more important) as the products they build. Once I begin questioning the integrity of the people who make up the team of a security organization, I question the stability of the company, and ultimately the products they build. Anyone can build a security product line, given the right resources. However, it is only companies with integrity can build a security product line they can stand behind, and no matter how big or small the company may be, that is what I believe everyone should look for, and it always starts with the people.

Sorry Health Care...Game Over!

Back in the day when pinball machines were all the rage at game arcades (and the only video game was pong), one could bear witness to a room full of pre-pubescent boys and girls (mostly boys as I recall) pumping quarters into machines and batting steel balls with rubber coated "flippers" in order to prevent the ball from falling into the shoot. The longer you could keep batting that ball the more points you would score. If you were particularly well versed in the art of pinball machines you could shake and tilt the machine to a degree (avoiding the inevitable "tilt" caused by being over-zealous) and perhaps score more points by making the ball move where you wanted it to move.

Nonetheless, this mastery of batting the ball and shaking and gyrating the machine came to an end for even the most skilled of pinball wizards. Many players would continue to shake and gyrate the machine after their last steel ball (back than you got at least 3 balls) had fallen, but there was simply no denying the reality of what the scoreboard prominently displayed in bold letters...GAME OVER !

Sure, those with paper routes or other sources of quarters could keep pumping legal tender into the system to give it another go around, but the result was inevitably the same. Eventually you have to give into reality. You can't bat the ball around forever.

The idea of health care organizations having to take responsibility for security and privacy in an ever expanding digital age is certainly not new. The first HIPAA regulations passed in 1996. I am no math genius, but that is about 14 years by my calculations. In 14 years, however, health care organizations and providers have been lax in dealing with security. I currently serve on the CalPSAB security steering committee, and that seems to be something we all agree on (actually, we seem to agree on a lot more than that). Having just returned from the Safeguarding Health Information: Building Assurance through HIPAA Security conference in Washington DC, it seems quite clear that the Office of Civil Rights (OCR) and Federal Trade Commission (FTC) are also aware that a lack of due diligence on the part of health care practitioners (and business associates) with respect to security and privacy has gone on long enough.

Nonetheless, we still see organizations (such as The American Medical Association, American Osteopathic Association and Medical Society of the District of Columbia) fishing for more quarters to pump into the machine.

Hey! Why not? They have plenty.

In an article published on the excellent Health Data Management Blog, the author references a lawsuit filed by the aforementioned entities. The essence of the lawsuit is that health care organizations do not want to fall under the authority of the FTC with respect to the "Red Flags" rule the FTC currently requires creditors to abide by. The (ridiculous) claim being made by the filers of the lawsuit is that (from the article):

Among other factors, the medical associations argue that physicians are not commonly referred to as "creditors," nor are patients ordinarily thought of as "account holders" or "customers."

Wow! Am I understanding this correctly? This is coming down to a definition of what a "creditor" or "customer" is?

At the Washington DC meeting one of my takeaways was that OCR is really putting the hammer down, and perhaps they should consider less "stick" and more "carrot" in dealing with organizations that have to comply with the rules. However, when I witness the equivalent of a bunch of pinball wizards banging on a machine as they fish for more chances to avoid the inevitability of owning up to the fact that batting balls around eventually loses its charm, I shed some of my sympathy.

The Health Care Industry simply cannot keep playing this game forever. It is time to focus their energy on ways to address security and privacy concerns in a meaningful way, and stop fighting what is inevitable.

GAME OVER!

Privacy: A Prescription For Disaster

I have been watching the world of cyber security unfold for the last several years in a manner I would best describe as divergently focused. As a security professional who frequently engages in deep (almost philosophical) discussions with other security professionals (or more appropriately, Security Warriors) I am constantly amused at the frustrations we seem to share about privacy being the biggest driver of security in emerging technological initiatives.

I recently wrote about this on the topic of Smart Grid security, and Gib Sorebo of SAIC followed up on his blog with his opinion. Gib and I have had some long and great discussions about the issue of privacy in a world of security vulnerabilities, and the one area that seems to get us both preaching is the issue of privacy as it relates to health care. Simply put, this is a good time to shift the security discussion to something that really matters, and I am sorry to say that privacy needs to leave the room for a while.

Okay, I am sure the entire world of privacy evangelists are probably going to want to send me that nasty fruitcake (or worse) they have been holding onto for the last 20 years after reading that last statement, but please hear me out before you head over to the post office. Privacy IS important and DOES MATTER to me and probably every security professional in this world. I am a strong supporter of privacy, and consistently do all I can to protect my privacy. I refuse to give my address and phone number at stores that ask for it when I pay with cash or ask me for that information for any reason whatsoever. I refuse to share ANY information with ANY entity that requests it that I deem is not on a need-to-know list, and have held up lines in stores, banks, and other places (sorry to all of you who stood behind me) defending my rights to my own information. Privacy is indeed very important in the digital world we are now completely enveloped in.

...but it has got to stop being a part of health care security discussions, or we are probably going to end up with a lot of dead people as a result.

In fact, we already are ending up with seriously damaged patients in the age of digital health care. I read an article on The Huffington Post this morning titled "Electronic Medical Record Shift: Signs Of Harm Emerge As Doctors Move From Paper" which pointed out how either bad information or a failure in software has led to patient trauma (heart attacks, seizures). The article did not speak of security issues that led to failures in these systems, yet the failures found in these systems serve to illustrate what I have been talking about for years. If a system is vulnerable to penetration and compromise by an attacker, the attacker can cause a lot more harm than a patient would suffer as a result of a privacy breach.

Let me specifically paint a scenario based upon the Huffington Post article. The first sentence of the article speaks of hospital workers misreading medical dosage information and dispensing 10 times the normal dose of a medication, leading to a patient heart attack. Under HIPAA HITECH, if an attacker should enter a system and change a single patient record (perhaps a patient who is a political figure) for a medical dosage to purposely cause a heart attack or death, the health care organization would be in violation of a privacy law, but could not be held liable for the death of the patient due to a failure in data integrity. In my opinion (and the opinion of others I have spoken to about this issue), there is something very wrong with this.

The problem becomes even more complicated when you add medical devices to the system. Medical devices have become increasingly "smart" and are now trusted devices on health care networks. Devices perform many functions in health care, and the information some devices are trusted with gathering is often used to make life or death decisions. A device which automates the process of typing blood and then sends the information to a patient record database is indeed one type of device that would fall into this category description. If an attacker could spoof such a device he could then populate the database with incorrect information that could kill a patient. Moreover, some medical devices have firmware that can be updated (and in some cases over a network connection), which opens up the possibility of rogue firmware that could be purposely introduced to cause havoc.

I bring this up because the cost of failure due to a privacy breach simply pales in comparison to the potential cost of failure due to a failure to deliver correct information to the system. One leads to embarrassment and potential financial headaches, the other leads to death. Why is this distinction important? Well, except for obvious reasons, it is important because in a world where risks are mitigated based on costs of failure from a LEGAL perspective (i.e. a finable offense), the actual cost of failure due to a privacy breach is infinitesimally small compared to to somebody dying. A good lawyer can potentially turn a $1.5 million dollar fine (the maximum fine for a single instance under HITECH) down considerably if he or she could convince a judge/jury that the punishment does not really fit the crime.

It happens all the time, in fact, in other industries. At one time I worked for a company that dealt in motor oil who faced millions of dollars in fines from the EPA for statutory violations, but the fine was reduced to a few thousand dollars because the violation simply did not lead to anyone being harmed. The potential for harm was very high (as is true with medical record breaches), but if nobody is actually harmed then a slap on the wrist is a common punishment (especially if you have a good lawyer). Sure, it may cost you in legal fees, but if you already have a staff of lawyers anyway it is not so hard to stomach.

HITECH is a good step in the right direction for better security, but it still completely fails to address the bigger issues. As we continue to build out our "internet of health care" and interconnect data sources at a national (and eventually global) level, the security risks grow at a nearly exponential rate. This is because attackers like to attack systems more as they get bigger simply because it has a bigger impact. We should not wait for theoretical dangers to manifest themselves before we address these issues. Security vulnerabilities of large infrastructures are well known enough today that a failure to pro-actively address them is simply nothing more than negligence, and the health care industry should act more responsibly.

They know better.

The Grid Reliability and Infrastructure Defense Act- Better Late Than Never

As I have discussed many times in the past, security is primarily driven by compliance.

Wait...let me back up for a moment.

While many organizations (and particularly those who are involved in The Smart Grid) are indeed elevating security on the priority scale of "things we gotta do", we can be certain that any organization that has felt the pain of an attack will do more to secure their deployments than one who has not had the displeasure of being "owned" by an attacker. While some may argue that this is not the best way to get security into a system, I will argue that it is indeed the most effective driver of security. It is human nature to react to known dangers rather than proactively defend themselves against them. Moreover, we tend to proactively secure ourselves only if the known threats are directly experienced. Simply knowing someone who has been mugged in "the city" is not enough to get most people to become exceedingly aware of their surroundings, after all.

So with the Smart Grid we are in a situation where vulnerabilities have been discovered, and many more have been theorized. While nearly everyone who is involved in Smart Grid is indeed paying attention to security, turning that into "action items" remains a bit nebulous. Utilities who are actively deploying AMI (such as PG&E and SCE) are indeed focusing what I believe are tremendous (and competent) resources on Smart Grid security, and others are paying close attention (as I have gathered from various Smart Grid groups I am involved in). Vendors have created cyber security specific positions and departments. Security consultants are now specializing in smart grid security consulting. The US Government has several groups addressing the issues (FERC, NERC, NIST, DHS, DoD) in various capacities, and the list goes on and on.

The reason I say this is all a bit nebulous is because so far we have been lacking an authoritative mandate for Smart Grid security. Sure, NERC has been working on compliance and auditing standards (NERC-CIP 002-009), but neither NERC nor any other entity has the CLEAR authority to "lay down the law" as far as Smart Grid security is concerned. Each individual state has the power to halt Smart Grid deployments (I would surmise) for any reason whatsoever, but at a national level it is still very laissez-faire. The unfortunate negative consequence of this is that states (such as California) have adopted a bit of a "hurry up and wait" mentality about security (despite the fact that California doing this with voting machines was an epic disaster). This is never a good thing, because if (and when) security issues manifest themselves, the typical response is to halt progress until a resolution is reached (again, such as happened with voting machines). This is, to say the least, very irresponsible, because as far as the Smart Grid is concerned we NEED to have it deployed NOW in order to deal with the ever increasing demand for electricity. Consider electric cars, for example. Exactly how do we expect to manage load if California has millions of electric cars plugged in and charging on a hot summer day? Our current system can barely manage the load with no electric cars on the road, with high peak air conditioning usage days leading to power outages. We NEED the Smart Grid.

I was happy to see an article on TheHill.com that spoke of the House passing the Grid Reliability and Infrastructure Defense Act (GRID) which seeks to up the ante on FERC to take control of security issues affecting the Smart Grid. I am not generally fond of Congress passing laws that serve to penalize those who do not comply, as this generally leads to more consternation and less solution (in my opinion). So I was happy to see a section of this bill which seem to instead focus on providing resources to entities that are deploying the Smart Grid. From the bill:

COST RECOVERY.—If the Commission determines that owners, operators, or users of the bulk-power system or of defense critical electric infrastructure have incurred substantial costs to comply with an order under this subsection and that such costs were prudently incurred and cannot reasonably be recovered through regulated rates or market prices for the electric energy or services sold by such owners, operators, or users, the Commission shall, after notice and an opportunity for comment, establish a mechanism that permits such owners, operators, or users to recover such costs.

Now I know this is not very specific, but it does seem to address perhaps the biggest concern businesses involved in Smart Grid deployment may have in addressing security - COST $$$$.

It is not a law yet, and it may indeed go through some changes (perhaps not for the better) as it makes its way towards becoming a law, but I have high hopes.

...and hope springs eternal.

The Need For A Security Paradigm Shift

I remember years ago, when Stephen Covey's bestseller The Seven Habits Of Highly Effective People was making its rounds throughout the business world, the introduction of the word "paradigm" in my vocabulary. I was working in a resort way back then and our director of operations used to love walking around and tossing the term out like Rockefeller gave away dimes to the poor. He was a great operations director, and certainly was not deserving of the gentle ribbing he took for the liberal use of a term that nobody in my world seemed to want to care about. Frankly, most of us cared more about changes in our scheduled shifts more than we cared about "paradigm shifts".

Still, I did indeed listen intently to what he had to say. I liked him a lot, and he liked me. He convinced me to read Covey's book, and I gained a better understanding of several concepts, most importantly the concept of the paradigm shift.

To summarize my understanding of it in as few words as possible is perhaps something I am incapable of, so I defer to a definition I found while perusing the venerable Wikipedia. Here is the section I found best describes it:

the historian of science Thomas Kuhn gave paradigm its contemporary meaning when he adopted the word to refer to the set of practices that define a scientific discipline at any particular period of time. Kuhn himself came to prefer the terms exemplar and normal science, which have more precise philosophical meanings. However in his book The Structure of Scientific Revolutions Kuhn defines a scientific paradigm as:

• what is to be observed and scrutinized
• the kind of questions that are supposed to be asked and probed for answers in relation to this subject
• how these questions are to be structured
• how the results of scientific investigations should be interpreted

The bullet points capture the essence of what I believe is absolutely critical as we continue to discuss the topic of securing the smart grid.

Anyone who knows me knows that I am generally a very positive person, and generally give most people the benefit of a doubt. However, you also know that I tend to not suffer foolishness lightly. I call things like I see them, and although I am sometimes way off base, I am on target often enough to cause those I target (using my Socratic methods) to feel a bit uncomfortable. To those of you who I have made uncomfortable, my apologies for making you feel uncomfortable. My intention is not to get you to dislike me. My intention is to get you to see things differently, or to get you to shift your paradigm.

What led me to this blog posting was an article I read titled Securing The Smart Grid by Elinor Mills. This article is a combination of what I believe is sound information layered with generous doses of conjecture. I am not going to get into what I believe is conjecture at this point, since that will indeed take more time than I have this morning. What I did find worthy of calling out, however, was a quote made by Jesse Berst of Smart Grid News:

Jesse Berst, managing director of the Global Smart Energy consultancy and founder of Smart Grid News, said he didn't see any reason why the energy industry wouldn't be able to secure the infrastructure as it modernizes.

"The physical security concerns me more than the cyber security because we've solved the cyber (security issues) for other big consequential infrastructures (like financial and Internet) and I think we can solve it to that same degree of safety for this one," Berst said.

Now let me preface this by saying that I believe Jesse's contributions to the entire world of Smart Grid are indeed beyond admirable. I read Smart Grid News on a daily basis, and find it to be a wealth of information. I will also be the first to admit that he is light years ahead of me (and perhaps a lot of people) in his understanding of The Smart Grid.

...however, his statement "...we've solved the cyber (security issues) for other big consequential infrastructures (like financial and Internet) and I think we can solve it to that same degree of safety for this one," truly left my mouth hanging open.

Are you kidding me?

Okay, maybe CNet took that out of context. God knows the media seems to do that with more frequency than we would like to see. So I will indeed work with the assumption that this may be the case, and dissect this statement as one that may indeed be put forth by someone who may not be aware of how a security professional (such as myself) might view it.

Let's start with the first part of the statement "..we've solved the cyber (security issues) for other big consequential infrastructures (like financial and Internet)".

Really?

I am not entirely sure where to start with this one. Let's just take financial to begin with, and describe how we have "solved" those issues. Despite having "solved" the cyber security issues with respect to the financial world, the financial industry still loses billions per year due to cyber attacks, and then passes these losses on to the consumer. One "solution" the financial industry put forth several years ago was PCI Compliance, which simply shifts losses to merchants, who then are forced to raise prices to cover the losses. Another "solution" is to jack up credit card fees and interest rates ("risk management" as they like to call it) to cover the losses that the financial industry cannot pass on to the merchants. Sadly, there is no way any consumer can avoid falling into this abyss. If I do not want to use credit cards I am hampered by having to write checks or use cash for anything and everything. I also must live with the cost of failure that cyber crimes impose on my merchants through higher prices.

Such is life. Do I get by despite this mess? Certainly! Is the problem "solved"? Nope! In fact, I am not sure it can ever be solved. What I am sure of is that we seem to be able to live with this particular cost of failure in cyber security, and that may indeed be good enough (for now).

It is the second part of the statement "I think we can solve it to that same degree of safety for this one", however, that got me to bolt out of bed and start writing. Here is where the entire world of Smart Grid security "apologists" need to go through the mother of all paradigm shifts. Solving the security issues to "the same degree of safety" where The Smart Grid is concerned does not quite seem to cut it, now does it? Let me explain.

Let's consider the cost of failure.

While we live in a world of hyperbole in the world of cyber insecurity, we now also live in a world where some of the inherent weaknesses in the Smart Grid security arena have made the transition from theoretical to proof of concept. Perhaps the most famous of these is the infamous Aurora Attack seen on 60 Minutes (that was when my phone started ringing). What that showed us was that the cost of failure in security could lead to power being shut down in some areas for months. Now I know that some of you are going to want to attack this by telling me that we can simply redirect power from elsewhere, and that is indeed true, but what you would probably leave out of that statement is the fact that redirecting power during the middle of a blistering summer heat wave is next to impossible, and I am quite sure that a malicious attacker (not just a script kiddie) is keenly aware of that.

...and there is more. A lot more in fact. Utilities are keenly aware of the issues, and so is our government, and they do indeed care A LOT about security. Way more than the media is willing to give them credit for. In fact, I have never seen an industry embrace the importance of security with such fervor as the power industry has in the last year. In California both PG&E and SCE have invested considerable resources in dealing with these issues. One member of the cyber security team at PG&E sent me a message at 10:50 PM several nights ago in response to a question I had (regarding a conference I am planning). I was surprised that he replied so late and he informed me he was still at work! When I asked him why, he told me that he (and others on his team) often work late. When I see this level of dedication from security professionals I do indeed feel quite comfortable about the work being done towards securing our grid, and so should others (in my opinion).

Nonetheless, there is a dire need for a paradigm shift in the discussions surrounding Smart Grid security. We cannot use examples where the cost of failure truly pales in comparison to the cost of failure when we have no electricity. Imagine, if you will, a scenario where someone hacks your bank account and takes all of your money. You contact that bank and it can take several weeks to get your money back. I know this to be true because I know someone who went through such a nightmare. Nonetheless, she did not go hungry or die. She had food in her house, and credit cards, and family and friends. It really amounted to a nasty inconvenience, and she got all of her money back eventually. The "degree of safety" built into the system was indeed more than adequate to deal with this situation, but nobody who has their nose to the grindstone in the world of Smart Grid security would consider this to be a valid presumption of having the situation under control. We are fortunate enough to have only a small (yet significant) fraction of our power infrastructure on The Smart Grid, and everyone involved is working hard to deal with the issues at hand.

Let us avoid out of context statements making their way into the public consciousness, which will inevitably lead to a loss in credibility for those who are working hard to resolve these issues. The public loves to dwell on the negative even more than the media loves to talk about it.

In other words, let's not fuel the naysayers.

Bravo PG&E! The Proactive Approach Always Wins

I am once again making my way through comments to the CPUC, and was extremely pleased to find a comment made by PG&E:

PG&E AGREES WITH THE CUSTOMER PRIVACY GOALS AND POLICIES RECOMMENDED BY CONSUMER PRIVACY ADVOCATES

A number of consumer groups have provided specific recommendations regarding customer privacy goals and standards in this proceeding, including the Center for Democracy and Technology, Electronic Frontier Foundation, Consumer Federation of California, TURN and the Division of Ratepayer Advocates.5 These recommendations generally urge the Commission to move cautiously and very carefully in updating or revising its existing rules on customer privacy, particularly third-party access to customer data. In addition, the consumer privacy advocates point out that there are certain sources of national “best practices” for protecting consumer privacy in all industries that the Commission should consider and endorse, such as the “Fair Information Practices Principles” developed over the years and cited by various federal agencies, such as the Department of Homeland Security.6

As PG&E pointed out in its opening comments, we adhere to existing, strict and precise Commission and statutory rules and standards providing for protection of customer privacy, and do not see the need to dilute or reduce those protections. However, after reviewing the comments and presentations by consumer privacy advocates, PG&E agrees that it is timely in

this proceeding for the Commission and all parties to “benchmark” the existing customer privacy protections in the Public Utilities Code and utility tariffs against the national consumer privacy standards and goals applicable to other industries and consumer services. This is particularly important to the extent that the Commission will need to establish and be able to enforce these privacy protections and cyber-security protocols against third-parties who may be granted access by customers to sensitive or confidential personal information. For this purpose, we agree that the Commission and interested parties should start with review of the “Fair Information Practices Principles” and other national consumer privacy laws and guidelines, and evaluate whether enhancements or improvements in current Commission and utility practices should be considered in light of those national guidelines. PG&E recommends that this “benchmarking” effort be an integral element of the utilities’ SB 17 deployment plans.

My take on this is that PG&E is indeed committed to not only dealing with security issues head on, but is also sensitive to the concerns of the various agencies who are voicing their concerns. Moreover, they are willing to voice their commitment directly with the CPUC and essentially tell the CPUC that the ball is in their court.

I look forward to other key players in Smart Grid coming forward with this level of commitment! PG&E has been a leader in Smart Grid since day one, and leadership is what drives excellence.

I anxiously await the CPUC's decision on this.