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NERC Intransigence Leaves States with Responsibility to Protect the Electric Power Grid

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The North American Electric Reliability Corporation (NERC), the electric power industry’s consortium, has recently forwarded a new draft “operational procedure” standard (EOP-010-1) to the Federal Energy Regulatory Commission (FERC) for approval
The North American Electric Reliability Corporation (NERC), the electric power industry’s consortium, has recently forwarded a new draft “operational procedure” standard (EOP-010-1) to the Federal Energy Regulatory Commission (FERC) for approval
A major impediment to action in protecting the North American electric power grid against major solar storm geomagnetic disturbance (GMD) and nuclear electromagnetic pulse (EMP) effects is that the electric power industry is (understandably) swayed by the familiar, the convenient, and the bottom line. Without a doubt, Carrington-class solar storms and EMP effects are unfamiliar. The North American electric power grid has never experienced them. These are ‘black swan’ events which, if we fail to take protective action, engender complete blackouts of large (possibly continental) scale regions of North America for months to years. Like it or not, familiarity and profitability are the touchstones of acceptability. Strategic advantage in public debate goes to the convenient. Thus the tendency is presently to downplay the likelihood of the long-term grid outages that would be caused by a major solar storm or nuclear EMP event.

To counter the ‘strategic advantage of the convenient,’ it is crucial to create public awareness of the existential consequences of these effects. This must include identifying important and pervasive misconceptions concerning GMD/EMP. A major misconception is that GMD/EMP effects can be countered solely by well-conceived ‘operational procedures.’ However, given the complexity of the possible combinations and permutations of multiple grid failure mechanisms from GMD/EMP, operational procedures will not suffice. For instance, operational procedures proved ineffective in preventing the 2003 Northeast blackout that was precipitated by a single failure point involving tree contact with a transmission line. Grid models indicate that GMD and EMP will engender hundreds to thousands of failure points. Also, once the effects hit, the grid fails very quickly. In 1989, during a moderate solar storm GMD, the electric power grid of the entire Province of Quebec went dark in 90 seconds – there was not enough time to implement operational procedures. The complexity and rapidity of grid failure during a Carrington-class event will overwhelm the ability of electric utilities to respond, to prevent grid failure using any suite of operational procedures, no matter how well-conceived and practiced.

The good news is that operational procedures are not needed if the grid is physically protected against GMD and EMP. Furthermore, affordable physical protection engineering techniques and hardware are available to protect the heavy-duty components of the generation and transmission systems against GMD/EMP. These components include extra-high voltage (EHV) transformers and generator stations. These grid elements represent the ‘long poles’ in the protection tent since their procurement and replacement timelines is measured in months and years. The cost for this protection is estimated to be in the single digit billions of dollars, a micro-fraction of the losses that would occur from a protracted blackout (based on National Academy of Science and Lloyds of London estimates, losses will be in the trillions of dollars). Physical protection is well worth the investment.

The North American Electric Reliability Corporation (NERC), the electric power industry’s consortium, has recently forwarded a new draft “operational procedure” standard (EOP-010-1) to the Federal Energy Regulatory Commission (FERC) for approval. NERC representatives have indicated that there are no plans to develop an analogous industry-wide physical protection standard. Thus individual states are well-advised not to wait for or rely on NERC operational solutions, but rather to seize the initiative in developing physical protection requirements and/or standards that will ensure that their electric power systems and services can operate through major solar storm GMD and nuclear EMP environments.

(George H. Baker is a Professor Emeritus at James Madison University)

 

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