Original Steelman
Critical infrastructure failures can impose large, systemic harms, so relying solely on voluntary cybersecurity practices risks underinvestment and uneven protection. Minimum standards establish a floor of essential controls (e.g., asset inventory, patching, access management, incident response) that reduce common, preventable failures and create clearer expectations for boards and regulators. Independent audits add credibility by verifying implementation rather than accepting self-attestation, helping address information asymmetry: the public and downstream customers cannot easily assess an operator’s cyber posture. Audits can also drive continuous improvement through findings, remediation plans, and benchmarking across operators. A baseline does not preclude risk-based enhancements; it can be designed as outcome-oriented and updated periodically to reflect evolving threats. Overall, the requirement aims to internalize externalities—operators’ security choices affect national security and public safety—while improving accountability and resilience across interconnected systems.