Four-star Gen. Wesley Clark retired from the Army after a 38-year career that saw him wounded as an infantry commander in Vietnam and rise to become commander of the U.S. Southern Command and the U.S. European Command. He helped write the U.S. National Military Strategy and Joint Vision 2010 for maintaining “full-spectrum” dominance.

Now he has turned his attention to the electric grid as co-chair of the National Commission on Grid Resilience. And he says the U.S. is not prepared.

“The grid is the fundamental infrastructure for the U.S. It’s more important than pipelines, transportation or anything else because everything depends on the grid,” he said Wednesday at the American Council on Renewable Energy’s Grid Forum. “If it ever goes down, we’re in enormous difficulty.”

Although the terrorist attacks of Sept. 11, 2001, and Russia’s attacks on the Ukrainian grid have increased vigilance in the U.S., Clark said, the nation lacks a way to coordinate its response or measure its success.

“Lots of different groups have made recommendations, and many of their recommendations have been adopted. But there’s no clearinghouse; there’s no report card; there’s no way of knowing how well we’re doing” in responding to cyberthreats, he said.

“We need to be more open … about what the threats are,” he said in an interview with ACORE CEO Gregory Wetstone. “It’s really hard to find out whether we’re in danger or not if you’re just a citizen or on a public utilities commission setting a rate. You don’t really understand the threat. We know our enemies understand the threat. The question is: Can we do a better job of conveying this to the American public?”

Centralize Oversight

Clark also called on the U.S. to centralize its oversight responsibility. “Someone on the National Security Council staff should be tasked with looking at grid resilience. They aren’t. There should be a congressional caucus that meets to look at resilience issues. There isn’t.”

The U.S. also should develop a “test bed” where contractors, technologists and utilities can “try their hand against the latest threat,” he said. “That’s the way we did it in the Army to develop new technology.”

Clark also called for an expanded transformer reserve and development of microgrids, starting with ones on military bases. “In the event of a major grid crash caused by, let’s say, hostile action or environmental conditions, we have isolated islands that are self-powered and have enough [power] to be able to spread to the local communities.”

Wetstone raised President Trump’s May 1 Executive Order 13920 banning certain grid components from foreign adversaries, complaining that it was too vague.

“We never knew what was banned. It just created a lot of uncertainty,” Wetstone said. “Guidance was promised by mid-September; then it was reframed that we would see a Notice of Proposed Rulemaking by the end of the year. So, obviously, all this is being punted to the Biden administration.”

“This is an example of how difficult it is to move forward in the grid resilience area,” Clark said. “If we were China, we’d have a central data repository, and we would know everything that’s ever been bought from any foreign supplier and it would be controlled. But we don’t have the inventory. We don’t actually know what’s out there. We do know the threat because it’s been detected. But we don’t know where the threat is.

“It’s one of the first issues that I hope the Biden administration will be able to get a grip on. It is an urgent problem,” he continued. “The executive order was a great first step. But it wasn’t executable.”

NERC responded to the executive order in July with a Level 2 alert seeking data on the presence of foreign-provided equipment in the bulk electric system, and the Department of Energy issued a request for information on utilities’ practices for identifying and mitigating supply chain vulnerabilities. In September, FERC issued a Notice of Inquiry seeking utilities’ comments on reliability risks posed by BES equipment originating overseas (RM20-19). (See FERC Opens Supply Chain Cyber Risk Inquiry.)

Clark said the commission will “continue to push this and keep this issue alive because otherwise, everybody sort of nods sagely when you say these things: Yes, it’s complicated; yes, it’s a risk. And then it’s business as usual until there’s a catastrophe. If you think COVID and the lockdowns are difficult … it really doesn’t compare to what could happen with a significant grid problem.”

Commission Recommendations

The National Commission on Grid Resilience issued a report in August that made nine recommendations:

• Congress should direct DOE, the Department of Homeland Security and the Director of National Intelligence to establish a central clearinghouse and decisional node for communicating full and accurate threat information to BES operators and electric utilities.
• Congress should establish a National Resilient Grid Authority, an independent agency staffed by rotating appointments of the country’s most highly qualified energy, cybersecurity and national defense experts from both the government and private sectors.
• Congress should direct the Department of Defense and DOE to establish a nationwide advanced resilience technology (ART) test bed network of long-duration, blackout-survivable microgrids on military bases and other critical federally owned facilities that are predetermined to be safely sited on stable lands free from flooding, wildfires and other high-impact disasters for the foreseeable future. These should be devoted to both immediate defensive capabilities and rapid development of advanced grid resilience technologies.
• FERC — in consultation with appropriate expertise at DOE and the Department of Interior, states actively procuring offshore wind energy resources and the relevant ISOs/RTOs responsible for the management of the onshore grid in their jurisdictions — should reform and strengthen interregional transmission planning, cost allocation and competitive bidding processes to better address the characteristics of widely dispersed renewable energy generation.
• Congress should direct DOE and DHS to create a voluntary central repository of information regarding security and resilience investments in the electric power system.
• Congress should pass a Resilience Investment Tax Credit that incentivizes investments in cyber and physical security transmission components and equipment that are American-manufactured, as well as electromagnetic pulse security measures at both the distribution utility and BES levels. It should also direct federal spending toward resilience and security investments in federally owned electric utilities and end-use federal facility energy applications such as grid-connected devices, electric vehicle fleets and charging infrastructure, and distributed energy resources.
• Congress should establish a bipartisan caucus on grid security that meets regularly to consider issues impacting the security and resilience of the U.S. electric grid. The National Security Council should lead a complementary interagency committee on grid security that acts as a liaison with the caucus.
• The White House and Congress should establish a secure ongoing domestic supply chain, manufacturing capability and labor skills sets for all critical components and whole equipment essential to the operational security of the bulk electric grid, particularly prioritizing the largest and longest lead time transformers. Further, Congress should make annual updates to the DOE’s “Large Power Transformers and the U.S. Electric Grid (2012)” and “Strategic Transformer Reserve Report (2017)” reports and deliver briefings on them to the NSC and Congress.
• The president should order climate impact modeling of a range of future scenarios to identify where it will be safe to site new and upgraded bulk electric transmission. These planning scenarios should take into account sites critical to national infrastructure, areas threatened by environmental impacts (including sea-level rise, extreme heat and climate-driven population migration), impacts to the national economy and enhancements that could be made by public-private partnerships.