Duke Energy (1) External Routable Connectivity. Duke like to request that the drafting team consider using technical terms, such as the inclusion of network layers, to clarify what Using network layers is meant by a bi-directional routable protocol”. “accessible...via to quantify exactly the types of connections that are considered routable” “externally will aid in the entity’s assessment of this criteria.(2) Protected Cyber Asset. Duke would suggest removing the parentheses from the definition. Duke does not understand their here. Family Of Companies (FOC) (Protected Cyber Asset) See comment regarding BES Cyber Asset. including OPC, GTC & GSOC Nebraska Public Power [A] The comments submitted by NPPD should be considered collectively as they District apply to the body of standards. If considered individually as they relate to specific standards or requirements, the intent of the comment, as well as its efficacy, will be difficult to judge. Each element of proposed verbiage should be considered along with proposed verbiage in other portions of the standard instead of with the draft verbiage.Does the definition of ESP presume the presence of an Electronic Access Point? In other words, does a BES Cyber System with no External Routable Connectivity fall within the scope of the CIP standards? Clarifying this point will the need for interpretation or a CAN later. [Proposed Verbiage] Electronic Security Perimeter (“ESP”): A network to which BES Cyber Systems are connected using a routable protocol, surrounded by a logical border and which are only remotely accessible through an Electronic Access Point(s). Alliant Energy [A]The comments submitted by Alliant Energy should be considered collectively as they apply to the body of standards. If considered individually as they relate to specific standards or requirements, the intent of the comment, as well as its efficacy, will be difficult to judge. Each element of proposed verbiage should be considered along with proposed verbiage in other portions of the standard instead of with the draft verbiage.Does the definition of ESP presume the presence of an Electronic Access Point? In other words, does a BES Cyber System with no External Routable Connectivity fall within the scope of the CIP standards?Clarifying this point will
Duke Energy (1) External Routable Connectivity. Duke like to request that the drafting team consider using technical terms, such as the inclusion of network layers, to clarify what is meant by “accessible...via a bi-directional routable protocol”. Using network layers to quantify exactly the types of connections that are considered “externally routable” will aid in the entity’s assessment of this criteria.(2) Protected Cyber Asset. Duke would suggest removing the parentheses from the definition. Duke does not understand their here. Family Of Companies (FOC) including OPC, GTC & GSOC (Protected Cyber Asset) See comment regarding BES Cyber Asset. Nebraska Public Power District [A] The comments submitted by NPPD should be considered collectively as they apply to the body of standards. If considered individually as they relate to specific standards or requirements, the intent of the comment, as well as its efficacy, will be difficult to judge. Each element of proposed verbiage should be considered along with proposed verbiage in other portions of the standard instead of with the draft verbiage.Does the definition of ESP presume the presence of an Electronic Access Point? In other words, does a BES Cyber System with no External Routable Connectivity fall within the scope of the CIP standards? Clarifying this point will the need for interpretation or a CAN later. [Proposed Verbiage] Electronic Security Perimeter (“ESP”): A network to which BES Cyber Systems are connected using a routable protocol, surrounded by a logical border and which are only remotely accessible through an Electronic Access Point(s). Alliant Energy [A]The comments submitted by Alliant Energy should be considered collectively as they apply to the body of standards. If considered individually as they relate to specific standards or requirements, the intent of the comment, as well as its efficacy, will be difficult to judge. Each element of proposed verbiage should be considered along with proposed verbiage in other portions of the standard instead of with the draft verbiage.Does the definition of ESP presume the presence of an Electronic Access Point? In other words, does a BES Cyber System with no External Routable Connectivity fall within the scope of the CIP standards?Clarifying this point will