Fairway
Annotated outline§101.630

The 14-section Cybersecurity Plan, annotated

What each section of a compliant plan contains, and — from the reviewer's side of the desk — what gets template plans returned. One plan may cover a fleet of similar vessels; it is marked SSI and never emailed.

This outline is not a template to fill in. A Cybersecurity Plan must reflect the measures appropriate to the risks in your own Cybersecurity Assessment — a reviewer is specifically looking for the thread between what your assessment found and what your plan does about it. Use this to understand the shape of the document and to interrogate anyone offering to write yours.

  1. 01

    Cybersecurity organization and identity of the CySO

    Who owns the program: the CySO designation by name, the alternate, 24/7 contact information, and how cyber responsibility maps onto your existing chain of command.

    What gets plans returned: A designation with no after-hours contact chain, or a CySO who appears nowhere else in the plan's procedures.

  2. 02

    Personnel training

    The annual all-hands program, key-personnel and OT-user tracks, the 5-day new-hire clock, and how third-party content was evaluated.

    What gets plans returned: Training described in the plan that the records cannot evidence — the first thing the job aid cross-checks.

  3. 03

    Drills and exercises

    The two-drill, one-exercise annual cadence, scenario selection, CySO participation in exercises, and how corrective actions feed amendments.

    What gets plans returned: A cadence promised at fleet level with no named owner and no calendar mechanism behind it.

  4. 04

    Records and documentation

    What is retained, where, for the two-year minimum, and how it is produced on demand at inspection.

    What gets plans returned: Records scattered across inboxes and personal drives — producible in theory, never in minutes.

  5. 05

    Communications

    How cyber information moves: who is told what during an incident, vendor notification obligations, and how SSI material is handled and never emailed.

    What gets plans returned: SSI handling asserted in one paragraph and violated by the plan's own distribution list.

  6. 06

    Cybersecurity systems and equipment, with associated maintenance

    Patching cadence, KEV remediation without delay, approved hardware and software, and how changes to critical systems are controlled.

    What gets plans returned: "Patched regularly" with no KEV process — the one patching obligation the rule makes explicit.

  7. 07

    Cybersecurity measures for access control, including the computer, IT, and OT access areas

    Account lifecycle, MFA coverage on IT and remotely accessible OT, least privilege, separate credentials for critical systems, and revocation on departure.

    What gets plans returned: MFA claimed broadly while the dispatch system, the TMS, or a vendor portal quietly lacks it.

  8. 08

    Physical security controls for IT and OT systems

    Who can touch what: locked spaces, logged HMI access, blocked or disabled unused ports, and the no-unauthorized-media rule.

    What gets plans returned: A wheelhouse USB port that charges phones — and boots media — with no control described.

  9. 09

    Cybersecurity measures for monitoring

    What is watched and by whom: log capture with restricted access, IT-to-OT connections logged and monitored, and alerting that reaches a human.

    What gets plans returned: Logging without review. A log nobody reads satisfies neither the rule's intent nor an incident reconstruction.

  10. 10

    Audits and amendments to the Cybersecurity Plan

    The annual independent audit, auditor-independence evidence, and the amendment clocks: 30 days owner-initiated, 60 days Coast Guard-directed, 96 hours on CySO or ownership change.

    What gets plans returned: The CySO auditing their own program — §101.630(f) prohibits exactly this.

  11. 11

    Reports of all cybersecurity audits and inspections, to include documentation of resolution or mitigation of all identified vulnerabilities

    Every audit and inspection report, and for each finding it raised, what was done about it. §101.650(e) puts risk-management documentation here and in Section 12; §101.630(f)(1) requires the CySO's certifying audit report be attached to the plan.

    What gets plans returned: A section that lists audits but not resolutions. The title says both, and a reviewer will look for the second half.

  12. 12

    Documentation of all identified, unresolved vulnerabilities, to include those that are intentionally unresolved due to owner or operator risk acceptance

    The open findings register, including anything the owner has decided to accept rather than fix — with the rationale. Risk acceptance is explicitly lawful; undocumented risk acceptance is not.

    What gets plans returned: An empty Section 12. Nobody believes a plan with no unresolved vulnerabilities, least of all a reviewer.

  13. 13

    Cyber incident reporting procedures in accordance with part 101 of this subchapter

    The NRC script with 1-800-424-8802, what §101.615 defines as reportable, the without-delay duty (§101.650(g)(1)), the parallel CISA notice for Part 6 entities, and where the incident record lives (§101.640).

    What gets plans returned: A procedure that names an agency but not a person: at 2 a.m., "report to the NRC" needs a who, not just a where.

  14. 14

    Cybersecurity Assessment

    The assessment report itself, or a summary with a reference to where it is kept — marked SSI, current within the year, and the thing every other section is supposed to rest on.

    What gets plans returned: An assessment older than twelve months, or one that does not match the asset list in Section 6.


The honest caveat

An outline is not a plan

The Coast Guard is currently holding full plan submissions while it finalizes review procedures, and it has seen template plans before — the return-for-revision cycle gives you at least 60 days to fix a returned plan, which is time the calendar may not have in mid-2027.

A plan worth submitting is grounded in a real assessment of your boats and your terminal, written in your operation's own facts. That is six to eight weeks of real work for a cooperative operator — not an afternoon with a document generator.

Printable

The NRC call-script card, the training-records template and the CySO chooser

Three documents for the duties in force and the designation ahead — built to what the Coast Guard checks. Free; we ask for a name.

Get them —

Want the plan written properly, once?

Fixed price, six to eight weeks, grounded in a real assessment of your fleet — and staged submission-ready for the day the Coast Guard opens the window.

Or call 303-848-9352 or email aaron@fairway.systems — a person answers within one business day.