Critical Infrastructure Protection

GridEx: Is This Exercise Enough to Protect Critical Infrastructures?

GridEx bottom line upfront

GridEx is a biennial exercise run by North American Electric Reliability Corporation (NERC). The latest iteration, GridEx IV, was held on November 15-16, 2017. Most Americans have never heard of GridEx and didn’t even know it was taking place. If fact, most people don’t really have a clear understanding of what “the grid” is and what role NERC (a private not-for-profit corporation) and the federal government play in regulating the grid.

Bottom line up front:

  • GridEx is a voluntary exercise designed to test the grid’s response to large-scale power outages.
  • GridEx lacks transparency – very little public information is available. NERC says: “Due to the sensitive nature of the scenario discussion, this exercise program is not open to the general public or the media. A public report will be available after the exercise concludes.”
  • GridEx is held for two days every two years.
  • Very limited overview reports are available to the public for the last three GridEx exercises. They don’t say much.

GridEx is too little, not often enough and with little transparency. While any exercise involving testing the bulk power system’s capabilities, resilience and response is admirable and seemingly useful, it seems to me that GridEx is the minimum necessary for the bulk power industry to avoid having the federal government step in – which no industry wants.

But is GridEx sufficient to protect the United States from the catastrophic, existential threats to the power grid? Unfortunately, the answer is no.

What is the grid?

NERC GridEx

The bulk power system – or “the grid” – is not really one thing. The grid is actually thousands of companies, both public and private sector, that operate in an interconnected system to facilitate the generation, transmission and distribution of electrical power. The grid is made up of power generation – such as power plants, wind turbines and solar farms, high voltage transmission lines that span long distances across the country and local distribution lines which bring the power from the street to your house.

This interconnected (and vulnerable) patchwork is what allows the United States to support her human population. Everything that enables 325 million people in the country to survive is wholly reliant on the grid. All of our critical infrastructures – food, water, fuel, transportation and medical systems are all 100% dependent on the grid.

How is the grid regulated?

GridEx FERCThe grid is self-regulated (similarly to Wall Street). The federal government under current law can’t tell “the grid” what to do. The North American Electric Reliability Corporation (NERC) is a not-for-profit corporation. It acts as the self-regulatory organization “whose mission is to assure the reliability of the bulk power system (BPS) in North America.” The Federal Energy Regulatory Commission (FERC) is an independent federal agency that regulates the interstate transmission of electricity, natural gas, and oil. FERC’s specific authority over the electric grid is to “oversee the reliability of the bulk power system.” The regulatory scheme of the grid between NERC and FERC is mind-numbingly complex. (Just the way most industries prefer their relationship with the federal government to be.)

The Energy Policy Act of 2005 added Section 215 to the Federal Power Act. This gave FERC the authority to certify an organization as an “Electric Reliability Organization” (ERO) which would develop reliability standards for the industry, subject to FERC’s approval. Yes, you read that right – the industry writes its own reliability standards.

On July 20, 2006, FERC certified NERC as the ERO. Other entities objected and administrative appeals and litigation ensued. Section 215 does give FERC the authority to “upon its own motion or upon complaint, may order the Electric Reliability Organization to submit to the Commission a proposed reliability standard or a modification to a reliability standard that addresses a specific matter if the Commission considers such a new or modified reliability standard appropriate to carry out this section.” In English, FERC can order NERC to develop a particular standard and submit it for FERC’s review and approval, but this again is very time consuming.

Thus, FERC (the government) can’t easily tell NERC (the industry) what to do: There is a convoluted and time consuming rule making process involved. Before FERC can order NERC to take any action, they have to issue a proposed rule, solicit and consider any public comments (including those of the regulated entities and their representatives) and then issue a final rule (which is subject to industry lawsuit). This can take an incredibly long time. In terms of “sausage making” this rule making process is no way to get anything done quickly. A final rule can literally take years to issue. In some contexts, perhaps this regulatory scheme makes sense, but the protection of the grid and the dependent critical infrastructures is a national security issue – an issue of survival for families and the country. But it gets worse.

There is no federal law that says that the grid has to protect itself from hazards and threats. In fact, as previously noted, “itself” is thousands of separate companies that regulate themselves through NERC. Our very survival is dependent on the industry’s willingness to do the right thing. They are not required to do the right thing. This is why, in my estimation, GridEx is the bare minimum that the industry felt they had to do to avoid the government getting off its slow and lumbering buttocks and doing something drastic to protect the grid – and the United States – from catastrophe.

GridEx is not sufficient to protect the United States from Catastrophe

The only thing standing between America and catastrophe are thousands of moving parts, a self-regulatory organization (NERC) and a regulator (FERC) with little actual power to protect us. Moreover, as we saw from the Great Northeast Blackout of 2003, a weakness in one of these thousands of moving parts can have cataclysmic consequences for the whole. In 2003, untrimmed foliage in Ohio started a chain of failures which resulted in a blackout for over 50 million people in the U.S. and Canada.

So, with the United States facing increasing threats from cyberattack, terrorism, electromagnetic pulse (EMP), geomagnetic disturbance (GMD) as well as the traditional threats to the grid, is a biennial (once every two years) two-day voluntary exercise enough? In the last GridEx (2015), only “364 organizations across North America participated in GridEx III, including industry, law enforcement, and government agencies.” 364 organizations out of thousands voluntarily participated.

The public reports from the three past GridEx exercises are not confidence inspiring. They lack detail about how the exercises were conducted. They are all spun to make each exercise seemingly a “success.” All objectives were met. Perhaps they were, but there is not enough detail to really assess how effective these exercises actually were. If you want to decide for yourself, here are the public reports.

In order for GridEx to be more meaningful, here is what should happen.

  • GridEx participation should be mandatory – this is an issue of national security.
  • GridEx should be held annually.
  • “Lessons Learned” should be turned to action items for NERC, FERC and DHS.
  • More information should be available to the public and press – In the GridEx III report, it actually said that they constructed the exercise reporting to thwart Freedom of Information Act requests!
  • The Department of Homeland Security should use this opportunity to implement the provision of the National Defense Authorization Act for FY 2017 that requires DHS to “include in national planning frameworks the threat of an EMP or GMD event.”
  • Congress should insist that the results of future GridEx events be reported to the House and Senate Homeland Security Committees.
  • Finally, local emergency management organizations across the country need to participate.

In sum, I am not against GridEx by any stretch of the imagination. I just think in its present form, GridEx is a paper tiger. And we live in a real jungle.

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Blackout: What we learn from electric grid failures

 

 

BlackoutWhat we learn from history is that we do not learn from history

 

I’ve always loved this quote from Benjamin Disraeli. But it occurs to me that perhaps what is more dangerous than not learning from history, is learning from history.

What most Americans have learned from their experiences with blackouts is quite dangerous: Our collective experience with blackouts is that they are temporary. The power will be back in a few hours (or days, at most) so all we need to do is wait it out. The power company will rescue us.

Maybe some of us are even “prepared” for a blackout and have a generator and some gas. Maybe we have 72 hours worth of canned food stored away like FEMA  tells us. Even in the Emergency Management world, every exercise comes to an end. Every hurricane comes to an end. Every blackout comes to an end. Moreover, we have the “edge effect” where there are always resources available from outside the blackout area to assist us until the power comes back.

We are complacent. “Blackouts are temporary” we think.Blackout

But what if the power went off and did not come back for a year? While Congress has studied – and failed to act – on this scenario for years, more and more people in Emergency Management are thinking about a long-term blackout scenario.

There have been several recent articles of note, including an article in Fire Engineering by Ken Chrosniak: Electric Power Blackout: The Power of One. Another good article to read is by Garrison Wells published by Emergency Management Magazine: Threat of Massive Grid Shutdown Increasing in Face of Disasters. If you are an emergency manager, you really need to read these articles: You and your jurisdiction are not prepared for a long-term blackout. And more recently, Eric Holdeman has blogged about electromagnetic pulse in Emergency Management Magazine online.

There can be no serious debate that our electric grid is vulnerable to a number of things, from terrorist attack, electromagnetic pulse weapon, solar flare to a good old fashion ice storm or errant tree branch. While a long-term failure is considered by some to be a remote possibility, the possibility is frightening. And now there is evidence that both Iran and North Korea are actively pursuing electromagnetic pulse weapons with the specific purpose of taking down the U.S. electric grid.

Does anybody out there really think that they wouldn’t do it? U.S. “retaliation” means little to either country. Taking out “the great Satan” (in Iran’s case) would be worth whatever we sent back – so our usual deterrent strategy is not helpful here.  There is an excellent article about this in the Washington Times by R. James Woolsey and Peter Vincent Pry: “When Iran goes nuclear: Failure to protect the nation would amount to dereliction of duty“.

In fact William R. Graham, Chairman of the congressionally chartered Commission to Assess the Threat to the United States from Electromagnetic Pulse (EMP) Attack noted in 2008 that:

BlackoutElectrical power is necessary to support other critical infrastructures, including supply and distribution of water, food, fuel, communications, transport, financial transactions, emergency services, government services, and all other infrastructures supporting the national economy and welfare. Should significant parts of the electrical power infrastructure be lost for any substantial period of time, the Commission believes that the consequences are likely to be catastrophic, and many people may ultimately die for lack of the basic elements necessary to sustain life in dense urban and suburban communities. In fact, the Commission is deeply concerned that such impacts are likely in the event of an EMP attack unless practical steps are taken to provide protection for critical elements of the electric system and for rapid restoration of electric power, particularly to essential services.

Okay. Even if there was a massive grid outage, somebody would rescue us, right? Wrong. The United States is completely unprepared. The sad thing is, we don’t have to be. Even if Congress fails to act, individual communities can do much to prepare for and mitigate such a scenario.

So, one of the most dangerous things we have learned from history is that blackouts are temporary events lasting hours or at most a few days. We are completely unprepared for a long-term national scale blackout. Until we start thinking about it, the lives of millions of Americans remain in peril. 9/11would just a minor incident on the scale compared to what a long-term national power outage would be.

But, it can start in your community. FEMA won’t be there to rescue us in a long-term national blackout. We will have to rescue ourselves.

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A compilation of news reports on the 2003 Northeast Blackout

References:

New York Times, November 11, 2013: The Blackout That Exposed the Flaws in the Grid

New York Times, August 15, 2003: The Blackout of 2003: The Overview; Power Surge Blacks Out Northeast, Hitting Cities In 8 States and Canada; Midday Shutdowns Disrupt Millions

New York Times, August 15, 2003: The Blackouts of ’65 and ’77 Became Defining Moments in the City’s History

CBC: The ‘Great Northeastern Blackout’ of 1965

CBC: 2003: The great North America blackout

Department of Energy Emergency Situation Reports: http://www.oe.netl.doe.gov/Emergency_sit_rpt.aspx

List of major power outages: http://en.wikipedia.org/wiki/List_of_major_power_outages

 

 

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Woolsey: Threat to electric grid ‘keeps me awake at night’

Mar. 06, 2015 Fox News – Former CIA director James Woolsey issues dire warning about the dangers a nuclear Iran poses to the U.S. electric grid – and our very survival.

Iran and North Korea are threats to the U.S. Electric Grid.

Read the Washington Times article by R. James Woolsey and Peter Vincent Pry: “When Iran goes nuclear: Failure to protect the nation would amount to dereliction of duty”. Here’s an excerpt:

James Woolsey: Threat to electric grid 'keeps me awake at night'The new factor that makes one or a few nuclear warhead-carrying missiles launched into orbit much more dangerous than during the Cold War is the possibility of an electromagnetic pulse (EMP) attack against the critical infrastructures that are the foundation of modern societies, especially the national electric grid. Electronics are increasingly vulnerable to EMP — more than a million times more vulnerable (and, yes, also much more capable) than they were at the dawn of the age of modern electronics a half-century ago. Moore’s Law has not been kind to our electronic vulnerabilities.

Consequently, even one nuclear warhead detonated at orbital altitude over the United States would black out the national electric grid and other life-sustaining critical infrastructures for months or years by means of the electromagnetic pulse it would create. The Congressional EMP Commission assessed that a nationwide blackout lasting one year could kill nine of 10 Americans through starvation and societal collapse. Islamic State-like gangs would rule the streets.

Just such a scenario is described in Iranian military documents.

 

James Woolsey: Threat to electric grid 'keeps me awake at night'

R. James Woolsey

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