By Rich Heidorn Jr. and Holden Mann

ATLANTA — NERC’s Board of Trustees last week accepted the EMP Task Force’s Strategic Recommendations report but pointedly did not endorse the panel’s suggestions, saying it will consider them after reviewing stakeholders’ comments.

The issue of electromagnetic pulses is a polarizing one, and at least some of the task force’s recommendations — notably calling for guaranteed cost recovery for investments to protect the grid — are hot potatoes for NERC. The draft Strategic Recommendations report, which was released for comment Aug. 30, also urged more access to classified information.

The report made 15 recommendations in four areas — research needs; vulnerability assessments; mitigation guidelines; and response and recovery — and suggested lead and support organizations for each, including NERC, the Department of Homeland Security and the Federal Emergency Management Agency. (See EMP Task Force Calls for Federal Funding.)

The trustees praised the task force for its research but gasped at the potential implications of its recommendations.

‘Complexity … Scares Me’

“Reading through that document — it puts things into context that are extraordinarily complex in a way such that you can begin to see how we might actually tackle this initiative,” Trustee Rob Manning said. “But the complexity is what scares me. The breadth of recommendations, the scope of those recommendations — it’s truly scary. So many people have to be involved. So much action has to be taken by so many different parties.”

Trustee Jan Schori said it was “very helpful” that the report suggests potential lead and support agencies for the recommendations — all 15 of which list NERC as lead or co-lead.

“I would be interested in input from those that comment on what role NERC should play going forward,” Schori said, noting “some of [the roles] are … not areas where we … have taken the lead.”

Schori also said she “can understand why the industry participants would be very concerned about … the question of cost recovery for work that is done” in response to any standard or guideline adopted by NERC.

“Traditionally, NERC is the technical resource. We don’t usually get into opining on cost recovery matters. And so … I’m very cautious about those parts of the report.”

A number of the industry comments pushed this theme, arguing that the task force’s recommendations gave NERC too prominent a role and often relegated more qualified bodies to a supporting function. For example, Ruida Shu, manager of reliability standards at the Northeast Power Coordinating Council, suggested that the Department of Energy should take the lead on providing educational materials relating to EMP preparedness, as “NERC is not equipped to engage in mass public educational endeavors.” In the same vein, representatives from Exelon and the Edison Electric Institute recommended that DHS replace NERC as the lead on coordination across utility sectors.

Taking questions about the task force’s perspective a step further, Robin Yee, adviser on U.S. affairs and grid security at the Canadian Electricity Association, objected to the U.S.-centric framing of the report and its lack of attention to the legal and regulatory requirements of other jurisdictions. Yee requested that “NERC develop a framework for ongoing consultation and dialogue between governments,” so that policies affecting the North American grid would take note of all relevant perspectives.

Kim Thomas of Duke Energy said the task force had failed to make use of “the full body of work already performed in the industry for this topic” and recommended NERC “acknowledge and utilize work-in-progress or completed for this topic [in order] to avoid duplication of work and to provide additional depth and understanding.”

No Confusion

“We don’t want any confusion on accepting the report as [representing] final approval of the recommendations,” said board Chair Roy Thilly, who promised the board would issue its recommendations on EMPs in February.

Thilly said the board will solicit additional comment from NERC management and others on the recommendations and what it should prioritize. “I suspect there are budget impacts and other resource impacts. So, we need to understand we can’t just approve the recommendations without knowing those factors. We do have work to do to get to February.”

The task force’s work was informed by a report released by the Electric Power Research Institute in April that concluded a high-altitude EMP caused by a nuclear explosion could cause a multistate electric outage but not the nationwide, monthslong blackout some observers fear. The report prompted a harsh critique by the Electromagnetic Defense Task Force. The group, which has ties to Maxwell Air Force Base, contends EPRI underestimated the risks and that relying on it would not address “remaining vulnerabilities impacting large power transformers, generating equipment, communication systems, data systems and microgrids designed for emergency backup power.” (See Critics: EPRI EMP Report Understates Risks.)

Next Steps

NERC Manager of Standards Development Soo Jin Kim, who presented the recommendations to the board, said the task force would like to begin Phase 2 of its work — more detailed analysis that would be forwarded to the newly created the Reliability and Security Technical Committee (RSTC). The RTSC would “develop detailed mitigation guidance and policy and procedures for how to update certain response and recovery plans,” Kim said.

“Only after the detailed work is done at the RSTC level — if it identified that there are enhancements or gaps in the standards, there [would] be an initiative for the EMP Task Force to kick off a standards development effort,” she said. “But that would only be if necessary, after the technical committee has first done its homework.”

In response to a question from Manning about proposed next steps, Kim said the task force identified as a “threshold question … that there needs to be progress in determining what’s an acceptable level of [bulk power system] performance during an EMP attack.”

She also noted that EPRI and several utilities are planning field trials of potential mitigation measures.

“Hopefully those field trials will be able to shed some light on certain mitigations and how available that technology will be to industry generally,” Kim said. “There’s also several research efforts going on right now with the National Labs. We have been reaching out to DOE and DHS also to try to share more information and to get more accurate information so industry can make those vulnerability assessments and accurately look at their systems.”

While some of the recommendations are outside the ERO’s authority, some are actionable by NERC and “will largely flow right into the RSTC next year as part of Phase 2,” she said. “We hope these recommendations will flow into the development of next steps for the industry to move forward in addressing EMP events.”

Not all industry participants were as positive about the momentum of the task force’s work: while Mark Gray, senior manager of transmission operations at EEI, described the report as a “good first step,” he said more research was needed to develop an effective response. Gray also recommended the removal from the report of language related to local distribution providers and other systems outside of NERC’s statutorily designated role.

Andy Dodge, director of FERC’s Office of Electric Reliability, asked whether the other agencies suggested as having roles have “bought into” the recommendations.

Kim said the task force followed President Trump’s March executive order in “highlighting some of the agencies that could be on point” and noted that the task force — formed in April — had a “very aggressive schedule” with the directive to provide recommendations to the board by November.

“Several of the entities that we did reach out to, and some of our contacts, stated that we probably would not be able to get some type of endorsement,” she said. “There has not been an official stance from any of the government agencies. Quite frankly, in that amount of time, I don’t think we could have received an official statement … that they would be willing to take on some of those recommendations.”

“Is NERC leadership going to follow up with these entities?” Dodge asked.

“Yes,” Thilly said, without elaboration.