On June 2, 2010, the North American Electric Reliability Corporation (“NERC”) and the U.S. Department of Energy (“DOE”) published their report entitled “High-Impact, Low-Frequency Event Risk to the North American Bulk Power System” (“HILF report”).  The report highlights risks that could have disastrous impact on the bulk power system, such as acts of war, terrorism, and coordinated criminal activity, but which are either rare or have never occurred. 

In July 2009, NERC and DOE formed a steering committee and held a two-day workshop in November 2009.  The HILF report summarizes the findings and proposals that were discussed in the workshop.  The workshop focused primarily on the risks of a: 1) Coordinated Cyber/Physical Attack; 2) Pandemic Illness; and 3) Geomagnetic Disturbance/Electromagnetic Pulse (“GMD/EMP”).  The workshop attendees included representatives from the Department of Defense, Department of Homeland Security (“DHS”), Federal Energy Regulatory Commission (“FERC”), congressional staff, and Department of Health and Human Services (“HHS”).

A cyber, physical, or blended attack on the bulk power system is described in the HILF report as one that would target multiple nodes on the grid in order to take down the security provided by traditional operation and planning.  An attacker would be able to manipulate assets and provide false data to system operators attempting to remedy any system disruption.  The report details nine proposals for action in an effort to prepare for a coordinated attack:

  1. A recommendation for more coordination and streamlined communication between DOE, DHS, and Canadian authorities;
  2. A recommendation that NERC direct its technical committees to formalize the process for evaluating and protecting the bulk power system from attacks;
  3. A proposal that NERC, DOE, and Canada work together to improve/create a spare equipment procurement effort and a consideration to re-launch the NERC Spare Equipment Database;
  4. A recommendation that NERC create a task force to develop analytical tools and models  to predict different scenarios under a potential attack;
  5. A proposal for NERC to direct its committees to develop operator training to handle physical or cyber attacks;
  6. A proposal for NERC to coordinate with other agencies and Canada in an effort to create a lexicon to communicate during an attack;
  7. A recommendation that NERC, DOE, and Canada develop a technology/software equipped with forensic and adaptive security controls to mitigate cyber attacks;
  8. A recommendation to continue and expand education programs that train students on the planning, design, and operation of the bulk power system; and
  9. A recommendation that DOE and Canada continue efforts to evaluate the supply chain for high impact system components.

A pandemic risk is described in the HILF report as a threat to the critical personnel that operate the system.  Without the critical personnel, inexperienced and lesser-qualified individuals would have to operate plants, address outages or mechanical failures, and operate the system.  During the 2009 A/H1N1 flu outbreak, the industry experienced a mild pandemic, and the electric sector is at the mercy of government health authorities regarding the spread and severity of the pandemic.   Thus, the report calls for clear triggers to the electric sector to make preparations for an outbreak.  The report also calls for the following actions:

  1. The electric sector should incorporate into their business plans a section on lessons learned from the 2009 flu outbreak;
  2. HHS and Canada should improve their timeliness, granularity, and quality of metrics used to report a pandemic;
  3. NERC and DOE should work with HHS to ensure critical employees are given priority for vaccines;
  4. NERC, DOE, and Canada should identify information needed to monitor workforce levels during an outbreak; and
  5. NERC should work with FERC and state regulators to relax penalties during an outbreak.

The HILF report also states that geomagnetic disturbances, or the earthly effect of solar weather, are becoming a growing threat to the bulk power system.  A geomagnetic current has the power to cause irreparable damage to large transformers and the widespread tripping of major transmission lines.  In addition, the use of a nuclear weapon or other type of electromagnetic pulse weapon could result in prolonged outages due to the damage to certain system components that are not readily available.  The HILF report called for the following to prepare for a GMD/EMP risk:

  1. NERC, DOE, and agencies in Canada should create a task force to evaluate and prioritize mitigation and restoration option in the case of a GMD/EMP event;
  2. Another proposal asks for an executive order to give weight to addressing GMD/EMP events;
  3. The creation of intergovernmental roadmap for long-term research, development, and deployment of mitigation options for GMD/EMP threats;
  4. NERC, FERC, DOE, DHS, and other agencies should work to develop methods for giving system operators region-specific, timely, and accurate information on a geomagnetic disturbance; and
  5. DOE, DHS, and Canada should work together to create an alert procedure that includes threat levels and an impending attack.

A copy of the full HILF report is available at http://www.nerc.com/files/HILF.pdf.