By Rich Heidorn Jr.

The electric grid cannot be protected against electromagnetic pulses (EMPs) without guaranteed cost recovery and more access to classified information, NERC’s Electromagnetic Pulses Task Force concluded in a draft Strategic Recommendations report released for comment Friday.

The task force, created in response to President Trump’s March executive order, said efforts to quantify the risks of EMPs and develop mitigation strategies have been hampered by limited access to classified data on attack scenarios and a dearth of research on the ability of grid components to withstand pulses. And the threat cannot be addressed, the task force said, without a public policy consensus.

The “threshold item that the ERO Enterprise should take the lead in addressing … is to determine the bulk power system expectations for an EMP event. Based on that information, the industry can make the necessary preparations for attempting to meet those expectations,” the task force said. “However, several policy matters, outside of the ERO Enterprise, will severely impact the electric sector’s ability to address an EMP event. Those policy matters include the lack of a cost-recovery mechanism and access to classified information regarding an EMP threat.”

The report makes 15 recommendations in four areas — research needs; vulnerability assessments; mitigation guidelines; and response and recovery — and suggests lead organizations for each, including NERC, the Department of Homeland Security and the Federal Emergency Management Agency.

It said the 13-member task force should be expanded and continue work in collaboration with NERC’s technical committees to develop vulnerability assessments, mitigation guidelines, and response and recovery plans.

Comments on the recommendations are due by Sept. 30.

Performance Expectations, Cost Recovery

The task force’s first recommendation is that the ERO Enterprise work with FERC, DHS, the Department of Energy and the Electricity Subsector Coordinating Council (ESCC) “to establish performance expectations for all sectors of the BPS regarding an EMP event” including survivability; expectations of ride-through versus recovery; restoration time frames; and permissibility of operations in a reduced protection state.

“This performance expectation will serve as the basis for industry with regard to where future mitigation efforts and capital expenditures should be most focused,” it said.

The task force said those performance expectations cannot be set, however, without “clear consistent cost-recovery mechanisms (federal financial support) for planning, mitigation and recovery plans.”

Policymakers should “consider establishing federal cost-recovery mechanisms for the electric utility industry to proactively address the performance expectations established by NERC,” the task force said.

“Effective EMP mitigation will span all portions of the electric sector: generation, transmission and distribution. The EMP Task Force highlights the importance of this recommendation in light of the variety of cost-recovery methods that exist across industry today, ranging from open competitive markets, to formula transmission rates, to traditional cost-of-service regulation.”

It suggested DHS take the lead on cost-recovery mechanisms, with support from NERC, FERC, asset owners, DOE and the ISO/ RTO Council.

The report makes no mention of state regulators, who approve distribution cost recovery and — in states with traditional vertically integrated utilities — also control spending on generation through integrated resource plans.

Trump’s executive order directed the federal government to provide incentives to “encourage innovation that strengthens critical infrastructure against the effects of EMPs through the development and implementation of best practices, regulations and appropriate guidance.” But the order made no mention of a federal funding stream for overall mitigation efforts.

Task force member Thomas S. Popik, president of the Foundation for Resilient Societies, said Congress did not address the funding issue when it enacted the Energy Policy Act of 2005, which created the ERO and gave FERC the authority to approve mandatory reliability standards.

The new system “was at its core an unfunded mandate on electric utilities,” he said in an interview with ERO Insider. “What wasn’t fully appreciated at that time was there would be additional standards for high-impact, low-frequency events — for example, cyberattack or electromagnetic pulse, even physical security — and that the reliability standards for [these events] would be many times more expensive than the previous voluntary standards, which were concentrated on operational procedures but not expensive hardware mitigations.”

Need for Declassification

The task force also recommended the creation of educational materials to inform industry and the public about EMP impacts on electronic devices and BPS stability. It said the ERO should provide guidance to the electric industry on coordinating responses with interdependent utility sectors such as telecommunications, fuel supplies and water. And it said NERC, DHS and FEMA should work with DOE and the U.S. Geological Survey to develop real-time notification system for informing system and plant operators of EMP events.

But it said those efforts will be hamstrung without more access to classified research by DOE, the National Labs and the Defense Threat Reduction Agency and to additional unclassified data on E1, E2 and E3 EMP “environments” — a reference to the three EMP “hazard fields.”

Data currently available “have very limited usability to the industry mainly because there are many parameters that are not shared with a greater audience,” the task force said.

A Bigger Challenge than GMDs

The task force said it relied in part on DOE’s 2017 action plan on EMP resilience and the Electric Power Research Institute’s (EPRI) April report on high-altitude EMPs triggered by nuclear weapons. Last week, a group affiliated with Maxwell Air Force Base released a harsh critique of the EPRI study, saying it underestimated the risks and should not be used as the basis for policymaking. (See Critics: EPRI EMP Report Understates Risks.)

The NERC task force said that improving the grid’s resilience to EMPs will be more difficult than the effort to address geomagnetic disturbances (GMDs). “The scientific evidence and basis of analysis for EMP events is not as well advanced and is likely to require some time to mature sufficiently to be of practical use,” it said. “Research conducted so far indicates that the impacts of GMD events tend to remain confined to longer lines operating at transmission voltage levels and interfaced to large power apparatus (e.g., generators and transformers). In comparison, the disruptive influence of an EMP event seems likely to span across the full spectrum of power system assets, including the transmission system, the distribution system, the protections and controls hardware, and the command-and-control infrastructure relied upon to monitor and maintain the power system in a stable operating state. Finally, the impact of an EMP event may extend to customer loads, since it remains unclear to what extent even these loads may be disrupted.”