Overview of FAA Rules 2024
Objective
The goal of the Federal Aviation Administration amended rules is to create new design standards that protect airplane systems from intentional unauthorized electronic interactions (IUEI), which can pose safety risks. The timely motivation for this goal is due to the ongoing trend in aircraft design, which features a growing integration of airplane, engine, and propeller systems, along with expanded connectivity to both internal and external data networks and services.
“This proposed rulemaking would impose new design standards to address cybersecurity threats for transport category airplanes, engines, and propellers. The intended effect of this proposed action is to standardize the FAA’s criteria for addressing cybersecurity threats, reducing certification costs and time while maintaining the same level of safety provided by current special conditions.” (1)
Background
Increasing integration of aircraft systems with internal and external networks raises cybersecurity vulnerability concerns.
Key vulnerabilities include:
- Field Loadable Software
- Maintenance laptops
- Public networks (e.g., Internet)
- Wireless sensors
- USB devices
- Satellite communications
- Portable devices and flight bags
Requirements for Applicants
Applicants seeking design approval must:
- Provide isolation or protection from unauthorized access
- Prevent inadvertent or malicious changes to aircraft systems
- Establish procedures to maintain cybersecurity protections
Purpose
“These changes would introduce type certification and continued airworthiness requirements to protect the equipment, systems, and networks of transport category airplanes, engines, and propellers against intentional unauthorized electronic interactions (IUEI)1 that could create safety hazards. Design approval applicants would be required to identify, assess, and mitigate such hazards, and develop Instructions for Continued Airworthiness (ICA) that would ensure such protections continue in service.” (1)
Key points:
- Introduce new design standards to address cybersecurity threats for transport category airplanes, engines, and propellers.
- Aim to reduce certification costs and time while maintaining safety levels similar to current special conditions
Applicant Responsibilities for Identifying, Assessing, and Mitigating IUEI Risks
The proposed rule requires applicants to safeguard airplanes, engines, and propellers from intentional unauthorized electronic interactions (IUEI). To do this, they must:
- Identify and assess risks: Find and evaluate any potential electronic threats that could harm safety.
- Mitigate risks: Take steps to prevent these threats from causing problems, ensuring the aircraft remain safe and functional.
Let’s break down each of the requirements:
Performing risk analysis
“For such identification and assessment of security risk, the applicant would be required to perform a security risk analysis to identify all threat conditions associated with the system, architecture, and external or internal interfaces.”(3)
Challenge
The complexity and variety of OT devices make it difficult and time-consuming to identify and associate CVEs with assets. Security teams face several challenges:
- Prioritization Issues: Sifting through extensive CVE lists to prioritize efforts is a struggle.
- Patch Complications: Finding corresponding patches is complicated by manufacturer delays and design flaws.
- Operational Constraints: Limited maintenance windows and the need for continuous operations make it hard to address vulnerabilities, often leaving them unresolved for years.
- Inadequate Assessments: Standard CVE assessments may not fully capture the risks associated with increased connectivity, underscoring the need for a contextualized risk assessment approach.
This highlights the need for a more effective and tailored approach to managing vulnerabilities in OT environments.
Assessing severity of risks
“The FAA would expect such risk analysis to assess the severity of the effect of threat conditions on associated assets (system, architecture, etc.), consistent with the means of compliance the applicant has been using to meet the FAA’s special conditions on this topic.” (3)
Challenge
As shown by the MITRE ATT&CK® Techniques for ICS matrices, threat actors can exploit many avenues beyond just CVEs. To effectively defend against these threats, security teams need a broader perspective, considering lateral movement and multi-stage attacks.
Challenges in Vulnerability Management (VM) cycles include:
- Initiation: VM cycles often start with email updates from the Cybersecurity and Infrastructure Security Agency (CISA), listing new CVEs from the NIST database.
- Communication: Security practitioners must survey and forward CVE lists to networking teams at facilities that might be running the affected assets. Responses from these teams are inconsistent, leading vulnerability managers to push patches that may not fit within limited maintenance windows.
- Asset Tracking: At many OT locations, determining if a company is running a specific firmware version can be extremely time-consuming. Teams often rely on spreadsheets and must perform manual checks by physically visiting production floors ("sneaker-netting").
- Coordination: Plant engineers and centralized security teams must exchange information to validate asset details and manually score vulnerabilities, further complicating and delaying remediation efforts.
Determine likelihood of exploitation
“Such assessment would also need to analyze these vulnerabilities for the likelihood of exploitation.” (3)
Challenge
Even when a vulnerability is identified, its actual impact can vary significantly based on the specific configurations, processes, and technologies in use within the organization. This creates challenges for OT security practitioners:
- Risk Assessment: Accurately assessing and prioritizing the risk becomes difficult without a clear understanding of how the vulnerability affects their unique systems.
- Decision-Making: Practitioners may struggle to determine whether immediate action is necessary, balancing the risk of operational downtime against the need for security.
- Potential Consequences: This uncertainty can lead to either leaving critical systems exposed or causing unnecessary disruptions by applying measures that aren't truly needed.
This complexity underscores the challenge of making informed, timely decisions in OT security environments.
Vulnerability mitigation
“The proposed regulation would then require each applicant to 'mitigate' the vulnerabilities, and the FAA expects such mitigation would occur through the applicant’s installation of single or multilayered protection mechanisms or process controls to ensure functional integrity, i.e., protection.” (3)
Challenge
OT security practitioners face a constant challenge in balancing security needs with the requirement to maintain operational uptime. In many OT environments, especially in critical infrastructure, applying security patches can be risky:
- Risk of Downtime: Patching can disrupt essential processes, leading to significant financial losses or even safety hazards.
- Operational Continuity vs. Security: Practitioners often prioritize operational continuity, sometimes delaying timely security updates.
- Alternative Strategies: To protect systems without direct patching, they must implement compensating controls, further complicating security efforts.
This delicate balance between security and uptime adds complexity to the already challenging task of securing OT environments.
Establishing procedures/playbooks
“Finally, each applicant would be required to include the procedures within their instructions for continued airworthiness necessary to maintain such protections.” (3)
Challenge
SOC teams typically have a lag before their response, leading to a higher dwell time and bigger overall costs. On average, only 15% of the total cost of ransomware is affiliated with the ransom itself (2). The rest is cost from business interruption. This means it's crucial that organizations can respond and recover earlier.
Darktrace / OT enabling compliance and enhanced cybersecurity
Darktrace's OT solution addresses the complex challenges of cybersecurity compliance in Operational Technology (OT) environments by offering a comprehensive approach to risk management and mitigation.
Key risk management features include:
- Contextualized Risk Analysis: Darktrace goes beyond traditional vulnerability scoring, integrating IT, OT, and CVE data with MITRE techniques to map critical attack paths. This helps in identifying and prioritizing vulnerabilities based on their exposure, difficulty of exploitation, and network impact.
- Guidance on Remediation: When patches are unavailable, Darktrace provides alternative strategies to bolster defenses around vulnerable assets, ensuring unpatched systems are not left exposed—a critical need in OT environments where operational continuity is essential.
- AI-Driven Adaptability: Darktrace's AI continuously adapts to your organization as it grows; refining incident response playbooks bespoke to your environment in real-time. This ensures that security teams have the most up-to-date, tailored strategies, reducing response times and minimizing the impact of security incidents.
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