How to Make Your Municipal Utility Use NIST to Protect Critical Infrastructure

Learn how your municipal utility can use NIST guidelines to safeguard critical infrastructure effectively and enhance security.

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Reviewed by Jeff Harms

Director, Advisory Services at OCD tech

Updated July, 24

What is NIST

What is NIST-Based Contracts for Municipal Utility

 

NIST-Based Contracts for Municipal Utilities

 

NIST-based contracts for municipal utilities represent formal agreements that incorporate cybersecurity requirements based on National Institute of Standards and Technology frameworks. These contracts establish security expectations between utilities and their vendors, protecting critical infrastructure that delivers essential water, electricity, and waste management services to communities.

 

Compatible NIST Frameworks for Municipal Utilities

 

  • NIST Cybersecurity Framework (CSF) - Provides flexible guidance specifically adaptable to the operational technology (OT) environments common in water treatment facilities and power distribution systems
  • NIST Special Publication 800-53 - Contains security controls that address the unique regulatory compliance needs of public utilities while protecting sensitive customer data and critical infrastructure systems
  • NIST Special Publication 800-82 - Focuses on industrial control systems security, directly applicable to SCADA systems that municipal utilities use to monitor and control water pumps, electrical substations, and treatment processes
  • NIST Special Publication 800-171 - Helps municipal utilities protect sensitive customer information and payment systems while ensuring proper access controls for utility workers

 

Benefits of NIST-Based Contracts for Municipal Utilities

 

  • Enhanced protection for critical services - Ensures vendors handling utility management systems implement appropriate safeguards that prevent service disruptions affecting entire communities
  • Standardized security language - Provides clear requirements for vendors servicing specialized utility systems like smart meters, SCADA controls, and customer billing platforms
  • Improved incident response - Establishes notification requirements when vendors discover security issues in utility-specific software or hardware
  • Risk-based approach - Allocates security resources based on the actual threats facing municipal utility operations rather than generic requirements
  • Regulatory alignment - Helps utilities demonstrate compliance with sector-specific regulations while maintaining public trust in essential community services

 

By incorporating NIST standards into vendor contracts, municipal utilities create a structured approach to securing both information technology and operational technology systems that communities depend on daily, while speaking a common security language with vendors that is widely understood across industries.

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NIST-Based Contracts Main Criteria for Municipal Utility

Explore NIST-based contracts and key criteria for municipal utilities to ensure compliance, security, and efficient public service management.

Risk Management Framework Integration

 

  • Contract must explicitly require the categorization of utility systems according to NIST FIPS 199, with special attention to operational technology (OT) systems controlling water, power, or other critical municipal resources
  • Vendor must demonstrate capability to implement tailored security controls for utility-specific environments where IT and OT systems converge, following NIST SP 800-53 controls
  • Agreement must include provisions for continuous monitoring of critical utility infrastructure with sensitivity to industrial control systems that may have unique operational constraints

 

Incident Response Capabilities

 

  • Contract must outline utility-specific incident response procedures that align with NIST SP 800-61, including specialized procedures for responding to incidents affecting service delivery to citizens
  • Vendor must provide 24/7 incident support with documented response times appropriate for critical municipal infrastructure
  • Agreement must include provisions for coordination with local emergency management during cybersecurity incidents that may affect public safety or essential services

 

Supply Chain Risk Management

 

  • Contract must require verification of all technology components used in utility systems according to NIST SP 800-161, with special emphasis on components that interact with operational technology
  • Vendor must document secure software development practices for any custom applications that support utility operations
  • Agreement must include vulnerability management procedures specifically designed for critical infrastructure environments where patching may require special scheduling

 

Compliance Documentation

 

  • Contract must require documentation of compliance with applicable utility-specific regulations (e.g., water quality, energy reliability standards) alongside cybersecurity requirements
  • Vendor must provide mapping between NIST frameworks and utility-specific compliance requirements
  • Agreement must include regular reporting templates designed to satisfy both municipal oversight bodies and technical security requirements

 

Business Continuity Requirements

 

  • Contract must include continuity of operations plans aligned with NIST SP 800-34 that specifically address maintaining essential utility services during cyber incidents
  • Vendor must demonstrate backup and recovery capabilities appropriate for operational technology environments, including provisions for manual operations if automated systems fail
  • Agreement must require regular testing of failover systems with minimal impact to ongoing utility operations

 

Security Assessment Provisions

 

  • Contract must require specialized testing methodologies appropriate for utility environments, including OT security assessments that won't disrupt critical services
  • Vendor must provide for regular security assessments that align with NIST SP 800-53A, adapted specifically for municipal utility operations
  • Agreement must include provisions for remediation planning that considers the unique operational constraints of public infrastructure systems

 

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Challenges Municipal Utility Face When Meeting NIST-Based Contracts

Explore key challenges municipal utilities face in meeting NIST-based contracts, including compliance, cybersecurity, and regulatory hurdles.

Resource Constraints

 

  • Municipal utilities often operate with limited IT staff and budgets compared to private sector organizations, making it difficult to implement comprehensive NIST controls
  • The technical expertise gap between current staff capabilities and NIST requirements often necessitates specialized training or external consultants
  • Implementing NIST standards requires sustained investment in security tools that may compete with operational priorities like infrastructure maintenance
  • Many municipal utilities lack dedicated cybersecurity personnel to manage the continuous monitoring requirements of NIST frameworks

 

Operational Technology Integration

 

  • Municipal utilities must secure aging industrial control systems (ICS) that were not designed with cybersecurity in mind but are still required to meet NIST standards
  • The convergence of IT and OT networks creates unique security challenges not fully addressed in standard NIST implementation guidance
  • Implementing security controls without disrupting critical utility services requires careful planning that balances compliance with operational continuity
  • NIST-based contracts often require vulnerability management processes that are difficult to implement on operational technology without risking service disruption

 

Compliance Documentation Burden

 

  • NIST frameworks require extensive documentation of policies and procedures that small utility staff must create and maintain alongside operational duties
  • Municipal utilities must develop and maintain system security plans (SSPs) that map their specific environments to hundreds of NIST controls
  • Contracts requiring NIST compliance often demand evidence of regular security assessments that must be produced with limited staff resources
  • The continuous documentation requirements of NIST frameworks create ongoing administrative overhead that diverts resources from service delivery

 

Public Sector Constraints

 

  • Municipal utilities face procurement challenges due to public sector purchasing rules that can delay implementing security solutions required by NIST-based contracts
  • As public entities, utilities must balance transparency requirements with the need to protect sensitive security information as required by NIST standards
  • Budget cycles in municipal government can create funding delays that complicate timely implementation of security controls required in NIST-based contracts
  • The multi-stakeholder governance structure of municipal utilities (involving city councils, boards, ratepayers) complicates and slows security decision-making processes

 

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Guide

How to Make Your Municipal Utility Use NIST to Protect Critical Infrastructure

How to Make Your Municipal Utility Use NIST to Protect Critical Infrastructure

 

Municipal utilities provide essential services that communities depend on daily—water, electricity, natural gas, and wastewater treatment. As digital systems increasingly control these services, your utility faces unique cybersecurity challenges that generic solutions can't address. This guide will help you understand how to leverage NIST frameworks to protect your municipal utility through effective contracting requirements.

 

Why Municipal Utilities Need Special Cybersecurity Attention

 

  • Municipal utilities operate critical infrastructure that directly impacts public health and safety
  • Many utilities rely on operational technology (OT) systems like SCADA that were designed for reliability, not security
  • Utilities often manage a complex mix of legacy and modern systems with long replacement cycles
  • Municipal organizations typically have limited cybersecurity budgets and expertise compared to larger private utilities
  • Local utilities are increasingly targeted by ransomware and nation-state actors seeking to disrupt essential services

 

Understanding NIST for Municipal Utilities

 

The National Institute of Standards and Technology (NIST) creates frameworks that help organizations manage cybersecurity risk. For municipal utilities, NIST offers practical guidance that can be incorporated into contracts with vendors and service providers.

 

  • The NIST Cybersecurity Framework (CSF) provides a flexible structure for managing cybersecurity risk across your utility
  • The NIST Special Publication 800-53 contains detailed security controls specifically applicable to industrial control systems used in utilities
  • The NIST Special Publication 800-82 offers guidance specifically for securing industrial control systems that manage physical processes
  • NIST Special Publication 800-171 helps protect sensitive information when shared with contractors

 

Step 1: Assess Your Municipal Utility's Current State

 

  • Conduct a critical asset inventory identifying all operational technology, information technology, and physical assets essential to your utility operations
  • Document connections between IT and OT networks (the business systems and the operational control systems)
  • Identify all third-party vendors and service providers with access to your systems or data
  • Review existing procurement language and contract requirements related to security
  • Assess your current incident response capabilities specific to utility disruptions

 

Step 2: Develop NIST-Based Contract Requirements

 

  • Tailor requirements to utility operations - Generic cybersecurity requirements won't address the specific needs of water treatment, electrical distribution, or other utility functions
  • Include sector-specific security controls from NIST SP 800-82 for industrial control systems
  • Require vendors to map their security practices to NIST CSF and demonstrate compliance
  • Mandate segmentation between business and operational networks for any connected systems
  • Specify secure remote access methods for vendors who need to maintain or update utility control systems
  • Require supply chain security verification for all hardware and software components in operational technology

 

Step 3: Incorporate Utility-Specific Security Requirements in RFPs

 

  • Include NIST-aligned security requirements in all requests for proposals for new systems, equipment, or services
  • Require vendors to provide documentation of security testing specific to utility environments
  • Ask for security-focused resumes of project team members who will work with critical utility systems
  • Mandate security design reviews before implementing new equipment or software
  • Request vulnerability management plans specific to utility operations that won't disrupt essential services
  • Require documented security incident response procedures that coordinate with your utility's emergency operations

 

Step 4: Develop Clear Contract Language for Utilities

 

  • Specify security controls from NIST SP 800-53 that apply to your specific utility systems
  • Include right-to-audit clauses allowing your utility to verify security compliance
  • Require regular security assessments aligned with NIST methodology
  • Mandate incident notification requirements with specific timeframes appropriate for critical infrastructure
  • Include security update and patching requirements compatible with 24/7 utility operations
  • Establish clear liability provisions for security breaches that affect utility services

 

Step 5: Implement Continuous Monitoring for Utility Environments

 

  • Require vendors to provide system activity logs that integrate with your utility's monitoring systems
  • Establish key performance indicators (KPIs) for security that reflect utility operational requirements
  • Implement automated monitoring for control system anomalies that could indicate attacks
  • Create vendor security scorecards to track compliance with contractual requirements
  • Schedule regular security status meetings with key vendors and service providers
  • Conduct annual security assessments of critical infrastructure systems

 

Practical Example: Water Treatment Facility Contract Requirements

 

  • Require chemical monitoring systems to have backup manual verification processes
  • Mandate independent security testing of SCADA systems controlling water treatment
  • Specify secure configurations for programmable logic controllers (PLCs) based on NIST standards
  • Require vendors to demonstrate physical and logical segmentation between internet-facing systems and treatment controls
  • Include incident response requirements coordinated with public health notification procedures
  • Specify minimum encryption standards for any remote system access

 

Practical Example: Municipal Electric Utility Contract Requirements

 

  • Require substation automation equipment to meet specific NIST-based security requirements
  • Mandate security design reviews for any smart grid technology implementations
  • Include operational technology backup procedures that don't rely on network connectivity
  • Specify physical security requirements for contractor access to critical infrastructure
  • Require secure development practices for any custom software controlling electrical distribution
  • Mandate secure firmware update processes that include verification steps

 

Overcoming Common Municipal Utility Challenges

 

  • Limited Budget: Focus first on securing the most critical operational systems that directly impact service delivery
  • Technical Expertise Gaps: Include requirements for vendors to provide security training specific to your utility's systems
  • Legacy Systems: Require vendors to document security compensating controls for systems that cannot be updated
  • Operational Constraints: Ensure security requirements account for 24/7 operations and safety priorities
  • Vendor Resistance: Develop a phased approach to implementing security requirements in contracts

 

Resources for Municipal Utilities

 

 

Next Steps for Your Municipal Utility

 

  • Form a cross-functional team including operations, IT, legal, and procurement staff
  • Identify your highest-risk utility systems that should receive priority attention
  • Develop a template for NIST-based security requirements specific to your utility
  • Review and update existing vendor contracts when renewal opportunities arise
  • Create a phased implementation plan that prioritizes critical infrastructure protection
  • Establish ongoing vendor security management processes with regular reviews

 

By systematically incorporating NIST-based security requirements into your municipal utility's contracts, you can significantly strengthen the protection of the essential services your community depends on, even with limited resources. This approach leverages national standards while addressing the unique operational needs of public utilities.

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Frequently asked questions

What services does OCD Tech provide?

OCD Tech offers a comprehensive suite of cybersecurity and IT assurance services, including SOC 2/3 and SOC for Cybersecurity reporting, IT vulnerability and penetration testing, privileged access management, social engineering assessments, virtual CISO (vCISO) support, IT general controls audits, WISP development, and compliance assistance for frameworks like CMMC, DFARS, and FTC Safeguards.

Which industries does OCD Tech serve?

OCD Tech specializes in serving highly regulated sectors such as financial services, government, higher education, auto dealerships, enterprise organizations, and not-for-profits throughout New England.

How long does an IT security assessment take?

Typically, OCD Tech’s on-site work spans 1–2 days, depending on complexity and number of sites, followed by 1–2 weeks of analysis and reporting to deliver clear, actionable recommendations.

Why should I get SOC 2 compliant?

SOC 2 reporting demonstrates to clients and prospects that an organization follows best-in-class controls over security, availability, processing integrity, confidentiality, and privacy—boosting trust, meeting RFP/due diligence requirements, and helping secure contracts. OCD Tech helps organizations achieve and maintain this compliance.

Can OCD Tech help me with federal cybersecurity regulations?

Yes—OCD Tech provides guidance for compliance with DFARS (NIST 800‑171), CMMC (Levels 1–3), and FTC Safeguards, ensuring organizations meet specific government or industry-based cybersecurity mandates.

What is a virtual CISO (vCISO), and do I need one?

A virtual CISO delivers strategic, executive-level cybersecurity leadership as a service. OCD Tech’s vCISO service is ideal for organizations lacking a full-time CISO and helps build programs, define policy, oversee risk, and guide security maturity.

Does OCD Tech offer ongoing security training or audits for staff?

Absolutely. OCD Tech provides tailored internal IT Audit training and security awareness sessions, plus annual reviews of Written Information Security Programs (WISP), such as Massachusetts 201 CMR 17 and other state or industry-specific controls.