CustodyTap

Estimate what your TCA and removable media records cost

Enter a few numbers about your program. The estimate runs in your browser, and nothing you type leaves this page.

For compliance leads at utilities that manage transient cyber assets and removable media under CIP-010 R4 or CIP-003 Attachment 1 Section 5. This is an estimate from our assumptions and NERC's published counts, not a measurement, and we'll update it as pilots give us real figures. See how it works.

Your program

Which BES Cyber Systems do these items connect to?

Laptops, test sets and relay programmers that connect for 30 days or less.

USB drives and other portable storage used on these systems.

How you record their use today

Self-logged, self-reported or found at audit, including disposal and reuse. Leave blank to use NERC's national counts.

Finding the authorizations, scan records and use logs for the items sampled. Leave blank to use 6 to 40 hours.

Change our other assumptions

Leave blank to use 12 to 52 for a transient cyber asset and 4 to 40 for removable media.

Leave blank to use $55 to $85.

Leave blank to use $65 to $100.

Each gets a short training in the first year. Leave blank to use 5 to 40.

Your estimate

 

Working out your estimate…

A year of TCA and removable media records, averaged over the simulations
SpreadsheetCustodyTap
Technician and compliance hours
Cost of that time
Setup, spread over 3 years
Tools and tags
Expected noncompliance costs
Total

* Before CustodyTap's own subscription, which isn't included anywhere on this page. † The time to investigate, mitigate and document each noncompliance, plus legal costs and a penalty for the few that go to a Notice of Penalty, weighted by how often they happen.

Noncompliance under CIP-010 R4 and CIP-011 R2, over a three-year audit cycle
SpreadsheetCustodyTap
Chance of at least one
Expected number
Chance of one that ends in a penalty

Nationally, about 95% of noncompliance closes as a Compliance Exception or Find, Fix, Track and Report, with no penalty. Most of the cost is the time each one takes.

How the estimate works

Your browser runs 10,000 simulations. Each one picks a value from a range for everything you didn't enter, then works out a year of records two ways, your current method and CustodyTap, with the same picks, so the two are compared fairly. The figures above are averages over those simulations, and the range shows where 8 in 10 of them fall.

What's an assumption

How long each method takes to record one use, review the logs each month, pull evidence for an audit and record a reuse or disposal, and how much of the noncompliance a complete record made at the time of use would prevent (we use 20% to 70%). CustodyTap's own figures are estimates of how the product is used. We haven't yet measured them at a utility. Most of the saving rests on them: if recording a use took as long with CustodyTap as with a spreadsheet, the estimate would fall by about half, and if the monthly review and evidence pulls took as long too, little would be left. A pilot measures them for yours, and we'll update this page as pilots give us real figures.

Where the noncompliance numbers come from

  • NERC's annual Compliance Monitoring and Enforcement Program reports count reported noncompliance by standard: CIP-010 had 182 in 2024 and 245 in 2025, CIP-003 had 133 and 100, and CIP-011 had 31 and 64.
  • NERC doesn't publish counts by requirement, so we assume 10% to 40% of CIP-010 noncompliance is R4, 15% to 50% of CIP-011 is R2, and 10% to 35% of CIP-003 is Attachment 1 Section 5.
  • FERC estimated in 2021 that 343 registered entities own medium or high impact BES Cyber Systems and 1,149 have low impact ones. By June 2025, 1,673 U.S. entities were subject to the CIP standards, so we use 343 to 450 and 1,149 to 1,700.
  • In 2025, 83% of dispositions were Compliance Exceptions, 14% were Find, Fix, Track and Report, and 2% went through Spreadsheet Notices of Penalty. CIP penalty amounts haven't been published since 2020, so we assume $0 to $250,000, plus legal costs, for the few that reach a penalty.
  • If you enter your own count for the last three years, it replaces the national figures. We add half an event so that a clean record isn't read as zero risk.

Where the pay figures come from

U.S. Bureau of Labor Statistics, May 2023: powerhouse, substation and relay repairers (median $96,600 a year) and compliance officers in electric power generation, transmission and distribution (mean $54.21 an hour), with benefits at about 30% to 35% of total pay.

What it leaves out

Time lost when an item can't be found before a job, vendor-managed transient cyber assets, and anything outside these requirements. CustodyTap's exceptions report may also surface issues that were going unnoticed, which can raise the count in the first year. It assumes technicians tap the tags: if they skip it, the saving shrinks.

What it isn't

It isn't a quote, a guarantee, or legal or compliance advice. CustodyTap supports evidence for these requirements; it doesn't make anyone compliant.

Measure it on one site

A pilot runs 90 days. We time how long your records take now and again at the end, so you can see your own figures, not ours.

Email David Brown

dbrown@enthropicdata.com