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Table of Contents

Executive Summary............................................................................................................................................. 2

Introduction: What the Nation Faces ................................................................................................................. 4

Recommendations and Supporting Findings...................................................................................................... 6

Moving Forward: A Call to Action ..................................................................................................................... 22

Appendix A: Acknowledgements...................................................................................................................... 23

Appendix B: Study Methodology ...................................................................................................................... 27

Appendix C: Definitions to Frame the Study..................................................................................................... 30

Appendix D: Government Authorities, Processes, and Roles........................................................................... 34

Appendix E: Sector Interdependencies............................................................................................................. 52

Appendix F: Individual and Community Preparedness Efforts......................................................................... 63

Appendix G: Lessons Learned from 2017 Disasters.......................................................................................... 67

Appendix H: References.................................................................................................................................... 72

About the NIAC

The President’s National Infrastructure Advisory Council (NIAC) is composed of senior executives from 

industry and state and local government who own and operate the critical infrastructure essential to 

modern life. The Council was established by executive order in October 2001 to advise the President 

on practical strategies for industry and government to reduce complex risks to the designated critical 

infrastructure sectors.

At the President’s request, NIAC members conduct in-depth studies on physical and cyber risks to 

critical infrastructure and recommend solutions that reduce risks and improve security and resilience. 

Members draw upon their deep experience, engage national experts, and conduct extensive research 

to discern the key insights that lead to practical federal solutions to complex problems.

For more information on the NIAC and its work, please visit: 

https://www.dhs.gov/national-infrastructure-advisory-council. 
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Executive Summary

The nation has steadily improved its ability to respond to major disasters and the power outages that often 

result. But increasing threats—whether severe natural disasters, cyber-physical attacks, electromagnetic 

events, or some combination—present new challenges for protecting the national power grid and 

recovering quickly from a catastrophic power outage. 

The President’s National Infrastructure Advisory Council (NIAC) was tasked to examine the nation’s ability 

to respond to and recover from a catastrophic power outage of a magnitude beyond modern experience,

exceeding prior events in severity, scale, duration, and consequence. Simply put, how can the nation best 

prepare for and recover from a catastrophic power outage, regardless of the cause? 

After interviews with dozens of senior leaders and 

experts and an extensive review of studies and statutes, 

we found that existing national plans, response 

resources, and coordination strategies would be 

outmatched by a catastrophic power outage. This 

profound risk requires a new national focus. Significant 

public and private action is needed to prepare for and 

recover from a catastrophic outage that could leave 

large parts of the nation without power for weeks or 

months, and cause service failures in other sectors—

including water and wastewater, communications, 

transportation, healthcare, and financial services—that 

are critical to public health and safety and our national

and economic security. 

What is a catastrophic power outage? 

• An event beyond modern experience that 

exhausts or exceeds mutual aid capabilities

• Likely to be no-notice or limited-notice and 

could be complicated by a cyber-physical 

attack

• Long duration, lasting several weeks to 

months due to physical infrastructure 

damage 

• Affects a broad geographic area, covering 

multiple states or regions and affecting tens 

of millions of people

• Causes severe cascading impacts that force 

critical sectors—drinking water and 

wastewater systems, communications, 

transportation, healthcare, and financial 

services—to operate in a degraded state Recommendations 

The United States should respond to this problem in two overarching ways: 1) design a national approach to 

prepare for, respond to, and recover from catastrophic power outages that provides the federal guidance, 

resources, and incentives needed to take action across all levels of government and industry and down to 

communities and individuals; and 2) improve our understanding of how cascading failures across critical 

infrastructure will affect restoration and survival. 

There are a number of ongoing initiatives in both the public and private sector that are in line with our 

recommendations. We urge the continued advancement of these initiatives in conjunction with our 

recommendations. 

The NIAC was challenged to examine events that are beyond our nation’s experience, yet would impact 

nearly every jurisdiction, industry, and citizen. The solutions we identified will require strong public-private 

collaboration—as the NIAC has recommended previously—to address the scale and significance of 

catastrophic power outages. 
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Next Steps

Our recommendations provide a path forward for enhancing the nation’s capabilities. These actions require 

a whole-of-nation approach and strong public-private collaboration. Given the importance of this issue and 

the number of ongoing efforts, we request the National Security Council (NSC)—working with the lead 

agencies identified—provide a status update to the NIAC within nine months of the report’s approval on 

how our recommendations are being implemented, progress being made on the ongoing initiatives, or any 

significant barriers to implementation. 
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Introduction: What the Nation Faces

Across the nation, we experience major threats nearly every year: hurricanes, wildfires, flooding, droughts, 

and other serious disasters. For these events, the nation has well-established response processes where the 

federal government serves as a backstop for the robust efforts of individuals, businesses, communities, and 

states. Even as severe weather increases, the nation has steadily improved its ability to respond to growing 

disasters and resulting outages—improving planning and coordination, hardening infrastructure, and 

building strong mutual aid agreements. 

The risk posed by a catastrophic power outage, however, is not simply a bigger, stronger storm. It is 

something that could paralyze entire regions, with grave implications for the nation’s economic and social 

well-being. The NIAC was tasked to examine the nation’s ability to withstand a catastrophic power outage 

of a magnitude beyond modern experience, exceeding prior events in severity, scale, duration, and 

consequence. 

The NIAC was challenged to think beyond even our most severe power disruptions, imagining an outage that 

stretches beyond days and weeks to months or years, and affects large swaths of the country. Unlike severe 

weather disasters, a catastrophic power outage may occur with little or no notice and result from myriad 

types of scenarios: for example, a sophisticated cyber-physical attack resulting in severe physical 

infrastructure damage; attacks timed to follow and exacerbate a major natural disaster; a large-scale 

wildfire, earthquake, or geomagnetic event; or a series of attacks or events over a short period of time that 

compound to create significant physical damage to our nation’s infrastructure. An event of this severity may 

also be an act of war, requiring a simultaneous military response that further draws upon limited resources. 

For the purpose of this study, the NIAC focused not on the cause, but rather on the consequences of an 

event, which are best categorized as severe, widespread, and long-lasting. The type of event contemplated 

will include not only an extended loss of power, but also a cascading loss of other critical services—drinking 

water and wastewater systems, communications, financial services, transportation, fuel, healthcare, and 

others—which may slow recovery and impede re-energizing the grid. 

Most importantly, the scale of the event—stretching across states and regions, affecting tens of millions of 

people—would exceed and exhaust mutual aid resources and capabilities. The ability to share public and 

private resources across businesses and jurisdictions underpins our nation’s emergency response plans and 

strategies today. (See Appendix C for a more detailed definition of a catastrophic outage). 

This profound threat requires a new national focus. The NIAC found that our existing plans, response 

resources, and coordination strategies would be outmatched by an event of this severity. Significant action 

is needed to prepare for a catastrophic power outage that could last for weeks or months. 

Our Task

In May 2018, the NSC tasked the NIAC to build on the insights gathered during a scoping effort to develop 

findings and recommendations on how the public and private sectors can work together to further 

enhance and integrate critical infrastructure resilience with response and recovery actions to mitigate 

risks posted by catastrophic power outages. 
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Our Approach 

To better understand catastrophic power outages and how they are different from previously experienced 

disasters, the NIAC conducted a scoping effort—completed in June 2018—to identify the key issues that 

would need to be further explored. A Working Group of 10 NIAC members led this full study, and formed a 

Study Group of subject matter experts to vet and validate the results of the scoping effort and provide a 

crucial input. In total, we interviewed more than 60 senior leaders and subject matter experts from federal, 

state, and local governments, industry, academia, and nongovernmental organizations (NGOs). We 

reviewed more than 700 resources, including statutes, regulations, reports, articles, congressional 

testimony, and prior studies. (See Appendix A for more information about the Working Group, Study Group 

and interviewees; and see Appendix B for more information on the Study Tasking and Approach).

Our recommendations seek to address the issues identified in two overarching ways: 1) design a national 

approach for catastrophic power outages that provides the guidance and incentives needed to take action 

across all levels of government and industry and down to communities and individuals; and 2) improve our 

understanding of how cascading failures across critical infrastructure will impact restoration and survival, 

enabling us to identify further actions needed to mitigate these failures. 

The federal government and industry are already leading many initiatives that are consistent with these 

recommendations. As set forth in subsequent sections, this study relies on and urges continued 

advancement of these initiatives. The study also encourages the adoption of new initiatives that will 

complement these ongoing efforts and lead to a better response to a catastrophic power outage.
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Recommendations and Supporting Findings

The complexity of the challenge posed by catastrophic power outages will require working across agencies, 

sectors, and levels of government to involve all stakeholders. For each recommendation, we identify a 

cabinet-level secretary to lead the effort and be responsible for implementation. We have also identified 

agencies that should provide support, including primary support roles for agencies that will need to provide 

significant input, expertise, and assistance. We also include supporting findings based on insights from 

interviews and research, and ongoing federal and industry initiatives that are consistent with our 

recommendations and should continue to be advanced and supported. 
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Design a national approach for catastrophic power outage planning, response, and recovery.

Current planning frameworks focus on sector-by-sector preparedness and response, but in a catastrophic 

power outage, U.S. infrastructure and services will fail as a system. We need to take a systems approach— 

from the federal level down to the local level—to plan, design, and respond to these never-beforeexperienced events. This approach must move beyond existing planning and response frameworks and 

provide the guidance needed for an integrated cross-sector, cross-government strategy. The 

recommendations in this section provide a path forward for establishing a national approach for dealing 

with catastrophic power outages.

Recommendation 1 

Examine and clarify the federal authorities that may be exercised during a 

catastrophic power outage and grid security emergency and clearly identify the 

cabinet-level leadership and decision-making processes. 

An event of this scale—with severe economic and national security implications—will require an 

unprecedented level of federal leadership, likely engage the military, and will see the federal government

exercise authorities that have rarely or never been used. Infrastructure owners and operators and state 

leaders recognize this conceptually, yet it is unclear how command authorities will change, who will make 

decisions, and how resources will be coordinated. 

A. Conduct an examination of federal emergency authorities and identify how they could be 

activated, by whom, and what implications they would have for private-sector, state, and local 

responders and ultimately how they would support Presidential action. 

B. Identify the cabinet-level officials who would take the lead in a catastrophic power outage 

and establish how these officials will coordinate and implement response with the public and 

private sectors, and state, local, tribal, and territorial (SLTT) governments to manage the cascading 

cross-sector impacts of these events.

C. Include and authorize catastrophic power outages as a high-priority mission for three 

key agencies: the Department of Energy (DOE), namely the Office of Electricity (OE) and Office of 

Cybersecurity, Energy Security, and Emergency Response (CESER); the Department of Homeland 

Security (DHS), namely the Federal Emergency Management Agency (FEMA) and the Cybersecurity 

and Infrastructure Security Agency (CISA); and the Department of Defense (DOD), namely U.S. 

Northern Command (NORTHCOM), U.S. Indo-Pacific Command (INDOPACOM), and the Defense 

Threat Reduction Agency (DTRA); and other agencies as appropriate. This authority should be 

underwritten with specific budget appropriations to provide the supporting resources necessary to 

achieve this mission, with clear roles and responsibilities identified for each agency. Identify and 

request that Congress provide any additional authorities and resources needed to execute the 

recommendations of this study. 

D. Enhance critical infrastructure sector participation at the National Infrastructure 

Coordinating Center (NICC) and National Cybersecurity and Communications 

Integration Center (NCCIC) to provide critical infrastructure sectors with a better 
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understanding of NICC and NCCIC operations, and position sector representatives to provide 

industry perspective and insights. Because catastrophic power outages are likely no-notice or 

limited-notice events, these key infrastructure representatives should be onsite full time to help 

identify issues and respond more quickly and efficiently.

i. At a minimum, the Electricity Subsector and Financial Services and Communications Sectors

should have representatives from the Sector Coordinating Councils (SCCs) or Information 

Sharing and Analysis Centers (ISACs), given the structure and organization of those sectors. 

ii. Other critical lifeline sectors, such as the Oil and Natural Gas (ONG) Subsector, Water and 

Wastewater Systems Sector, and Transportation Systems Sector should work with DHS to 

determine the appropriate representatives and level of engagement at the NICC and NCCIC 

to quickly and effectively engage and provide advisory input during a catastrophic power 

outage. 

Lead: Secretary of Homeland Security

Support: Department of Energy (Primary), Department of Defense, and other agencies as 

appropriate 

Supporting Findings

• Existing frameworks do not identify who has ultimate decision-making authority or clearly define 

the roles to be undertaken by SLTT governments and the private sector during a widespread, 

multi-state catastrophic power outage that will require coordinated cross-sector, cross-government 

response. 

o While incident command and unified coordination frameworks generally work, if an incident 

goes beyond a confined geographic area, these frameworks start to lose effectiveness due 

to the increased size of the impact area, the number and diversity of members in unified 

coordination groups, and the complexity of the response.

o Critical infrastructure owners and operators have limited visibility into how the federal 

government will manage an event of this size, and how the federal government will be 

working with the private sector to make critical resource decisions. 

o Although emergency authorities are understood at a high-level, how they are implemented 

in practice is unclear. There is a better understanding for physical events that are more 

frequently practiced, such as the preparation or response to a natural disaster; but how 

emergency authorities would be implemented for cyber-physical events and larger-scale 

disasters is less clear. 

o The Power Outage Incident Annex to the Response and Recovery Federal Interagency 

Operational Plans (POIA) outlines the responsibilities of federal organizations involved in 

response and recovery during a long-term power outage (defined as 72-hours or more). 

However, it is unclear how POIA would be used in practice and what specific federal entities 

will actually make priority decisions during a catastrophic power outage.1

 

1 FEMA, Power Outage Incident Annex, 2017. 
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• The federal government and military organizations have enormous support resources for an event 

of this scale, but an efficient response requires close coordination of those resources and 

capabilities with those in the private sector and whoever is in charge of the response, and there may 

be competing needs for those resources and capabilities necessitating tough calls on prioritization. 

• SLTT leaders and owners and operators have the best understanding of the needs of their 

community and can provide valuable information on how to make the most effective allocation 

decisions with limited available resources. 

• See Appendix D for more information about federal authorities, roles, and processes.

Ongoing Initiatives

• National Response Framework (NRF) Update: FEMA is updating the NRF with a goal to increase the 

emphasis of the role of the private sector and individuals in emergency response; add an emergency 

support function (ESF) to coordinate government and industry response; and focus on outcomes 

and prioritizing rapid stabilization of lifeline functions. As part of this process, the NIAC recommends

FEMA should: 

o Engage all stakeholders including SLTT governments, NGOs, and private sector owners and 

operators to ensure the new framework is accessible and understood by all stakeholders. 

o Consider practical and actionable ways to best leverage industry during the response to 

restore critical lifeline sectors more quickly and efficiently. 

o Exercise the National Cyber Incident Response Plan with the private sector to identify how it 

will work operationally during a real-life scenario and support the NRF. 

• DOE Emergency Authorities: Building on 10 C.F.R § 205, DOE is working with Grid Security 

Emergency (GSE) stakeholders to outline how an emergency order is communicated and build 

exercises to better understand what conditions the federal government may support during a GSE.2

 

o Potential emergency orders and provisions should account for regulatory, cost, and liability 

issues that may speed up the ability to issue and implement orders during a catastrophic 

power outage when timing will be crucial.

o This process should also establish a role/structure for private sector owners and operators 

to provide crucial analysis to inform the declaration of a grid emergency. 

 Monitoring and assessment capability must be in place and survivable against 

adversary attack and subversion. 

Recommendation 2 

Develop a federal design basis and the design standards/criteria that identify what 

infrastructure sectors, cities, communities, and rural areas need to reduce the 

impacts and recover from a catastrophic power outage. 

The design basis should take into account the cross-sector implications and cascading service failures of a 

catastrophic power outage. The design basis can guide planning and mitigation efforts, serve as a basis to 

develop appropriate incentives and investments, and provide the framework needed for investments to be 

made over time. 

 

2 Administrative Procedures and Sanctions, 10 C.F.R. § 205. 
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A. Develop design criteria and/or standards for critical infrastructure hardening, backup 

power, blackstart capabilities, fuel supply requirements, back-up communications requirements 

(including a standardized mobile command center design), food and water considerations, and 

other requirements that communities and businesses can build to. 

B. Expand the National Institute of Standards and Technology (NIST) Community 

Resilience Program to include the catastrophic power outage federal design basis criteria.

C. Share the DHS National Risk Management Center’s (NRMC) national critical function

analysis and analytical capability with SLTT governments and critical infrastructure owners and 

operators to help inform these decision-makers as they identify state and community-level critical 

functions that must be prioritized for restoration and hardening investments. 

D. Assess the economic and socioeconomic impacts of a catastrophic power outage on 

critical infrastructure and the ability of the national economy to withstand and recover from such 

events. The Council of Economic Advisers is well-positioned to conduct this assessment. 

i. The results of this analysis are needed to better understand the financial implications of the 

catastrophic power outage and how the economic risk should be factored into planning and 

recovery. It is also necessary to provide the economic justification for meeting enhanced 

design criteria and preparedness standards. 

ii. The analysis should also examine and identify any barriers to federal financial support 

services for tribal, territorial, and insular governments to ensure these entities have access 

to the resources they need to respond and recover from catastrophic events given the 

economic and geographic limitations some face. 

Lead: Secretary of Homeland Security 

Support: Department of Energy (Primary), National Risk Management Center, National Institute 

of Standards and Technology Community Resilience Program, Council of Economic Advisers, and 

other federal agencies as appropriate

Supporting Findings 

• There are no coordinated, consistent standards or design criteria for increasing resilience to a 

catastrophic power outage that industry and government could work toward over time.

o Companies and SLTT governments need time and justification to support making 

investments in more resilient infrastructure. A federal design basis could provide the 

guidance for a more coordinated and incremental increase in resilience. 

• There is no common agreement on the level of redundancy or resilience that should be built into 

critical utilities—such as energy, water and wastewater, and communications—to lessen the risk 

and impacts of a long-term catastrophic power outage. 

o Without design basis guidance from the federal government, it is difficult for owners and 

operators to justify investments, receive regulatory approval, or even know what standards 

are realistic and sensible to build to because everything cannot be hardened. Sectors will 

also continue to build based on siloed or individual requirements without taking into 

account the larger context of national or other critical functions. 
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• There is a lack of understanding of the cascading, cross-sector interdependencies between 

infrastructure and what that means for prioritizing backup generation and other limited resources 

to maintain services and functions during a long-term, widespread outage. 

o Hospitals and other mass care providers are often at the top on priority restoration lists, 

however, for example, some of the water and wastewater treatment facilities they rely on 

are not. Without working water or wastewater systems, hospitals are unable to function. 

There may even be a lack of understanding of which hospitals are the most critical to 

prioritize for restoration. 

• There is no common understanding of how long downstream sectors should be prepared to go 

without power, and what other services could be affected by the cascading impacts of a 

catastrophic outage. 

• See Appendix D for more information on federal and state government roles, and Appendix F for 

more information on sector activities. 

Ongoing Initiatives

• The NIST Community Resilience Program—part of NIST's broader disaster resilience work—is a

program designed to 1) develop the technical basis for tools to assess resilience and support 

informed decision-making for communities of all sizes; and 2) conduct outreach to community 

stakeholders to inform the development of NIST community resilience guidance tools for planning 

and implementing resilience measures.

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• The NRMC was established to provide a central location for collaborative, sector-specific and 

cross-sector management efforts to protect critical infrastructure. Within this, the NRMC will 

identify national critical functions through risk registries and dependency analyses with a focus on 

lifeline functions, and develop a strategic framework to identify critical cyber supply-chain elements 

across critical infrastructure sectors.4

Recommendation 3 

Develop guidance and provide resources for states, territories, cities, and localities 

to design community enclaves—areas that co-locate critical services and resources 

to sustain surrounding populaces, maintain health and safety, and allow residents 

to shelter in place. 

Community enclaves are not new mass shelters or camps; rather, they would generally consist of existing 

facilities and their supporting infrastructure, strategically located across communities to prevent mass 

migration or support survival when migration is not possible or residents must return as the outage persists.

A. Identify the critical lifeline functions that communities need (even in a limited capacity or 

degraded state)—such as communications, electricity, fuel, limited financial services, food, water 

and wastewater, and medical facilities—and for how long (e.g., 30-45 days). 

i. Integrate this guidance into the NIST Community Resilience Program. The guidance must 

include standards such as the number of hospitals, grocery stores, retail providers, gas 

stations, etc., based on population. 

 

3 NIST, “Community Resilience Program,” Webpage. 4 DHS, “DHS National Risk Management Center,” Webpage.
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B. Support demonstrations of community enclave design approaches, which may range from 

traditional hardening of infrastructure to microgrids that combine distributed energy resources, 

energy storage, and innovative consumer technologies. Deliver peer-reviewed results and lessons 

learned from demonstrations to provide utilities and communities with effective approaches to 

design, manage, operate, and fund microgrid and energy resilience capabilities. 

C. Develop and support voluntary assessments of critical functions at the SLTT level to 

help identify the existing infrastructure—electricity corridors, drinking water and wastewater, 

natural gas and liquid fuel pipelines, gas stations and fuel distribution sources, grocery stores, 

schools, hospitals, etc.—to create the community enclave. 

i. SLTT governments should use the voluntary assessments to inform emergency 

preparedness planning efforts to prioritize restoration of the infrastructure supporting the 

enclave, and to direct investments to harden this infrastructure as they are able. 

ii. The newly formed NRMC’s work to identify national critical functions could serve as a 

starting point and be expanded to conduct these voluntary state and local assessments. 

iii. The voluntary assessments must take into account the different challenges and needs of 

states and communities, including territories and isolated areas, and at-risk or vulnerable 

populations. 

D. Develop and conduct outreach and training for businesses and individuals to build a 

culture of preparedness at the individual and household level. Community enclaves are predicated 

on the idea that the majority of U.S. citizens are prepared and able to safely shelter in place for 

extended time periods. 

Lead: Secretary of Homeland Security 

Support: Federal Emergency Management Agency (Primary), Cybersecurity and Infrastructure 

Security Agency (Primary), Department of Energy, and the National Institute of Standards and 

Technology Community Resilience Program 

Supporting Findings

• Given the growing frequency and severity of disasters and other risks, there needs to be an increase 

in individual accountability and enterprise and community investment in resilient infrastructure. 

o There is a misconception that events occur infrequently.

o There needs to be more individual accountability for preparedness. 

• Resilience at the state and local level will be critical to enable people to shelter in place and 

facilitate faster recovery. Any event that requires a mass evacuation will use up critical resources, 

clog transportation pathways, and reduce the workforce necessary for infrastructure recovery. 

• Electricity, fuel, clean drinking water, wastewater services, food/refrigeration, emergency medical 

services, communications capabilities, and some access to financial services have been identified as 

critical lifeline services that would be needed to sustain local communities and prevent mass 

migration. 

• Any efforts at the community level need to include input from SLTT governments, NGOs, critical 

service providers, and community leaders. 
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o People default to trusted leaders and institutions (e.g., local government officers, 

faith-based centers, schools, civic organizations) in their community. 

• Rather than building new infrastructure, existing community infrastructure (e.g., a school, a mall, or 

an indoor stadium) could be upgraded using agreed upon resilience standards (e.g., fuel, power, 

communications, etc.), thus creating local resilience centers quicker and at less cost than building 

new ones.

o This level of planning and coordination will require a massive, interconnected analysis of the 

interdependencies, state processes, and maximum capacities for fuel storage.

• Florida Power and Light has established a model for identifying and hardening “community 

circuits”—electric distribution lines and substations that feed power to sites where multiple critical 

lifeline services are provided to communities. This could be expanded beyond electricity to the 

infrastructure needed for fuel resupply, communications, water, and wastewater. 

• A reliable fuel supply will be critical for establishing community enclaves and requires a baseline 

understanding of current storage and distribution capabilities. 

o Emergency fuel supply needs, fuel transportation requirements, the availability of backup 

generation, and the mutual interdependency of gas and electricity must be clearly 

understood by all stakeholders. 

o In most cases, in-state fuel resources will not be sufficient to meet the need for a 

catastrophic power outage.

• NIST community resilience planning guidance and tools are designed to be community driven and 

incorporated into existing efforts. The program encourages counties, cities, and communities to 

define what resilience should look like for them and then build it into all community actions. 

o NIST has also done work identifying building clusters or the buildings that provide crucial 

services or functions within communities. Those communities can then develop 

performance goals around those clusters. 

• A key challenge for community enclaves will be the last mile of distribution and resupply of 

resources. To address this, enclaves should take advantage of industry efforts and pre-existing 

capabilities. 

o For example, partnering with companies that have pre-existing robust distribution systems 

and distribution warehouses. 

• People no longer keep enough essentials within their homes, reducing their ability to sustain 

themselves during an extended, prolonged outage. The nation needs to improve individual 

preparedness. 

o Most preparedness campaigns call for citizens to be prepared for 72 hours in an emergency, 

but the new emerging standard is 14 days. 

o For example, Washington, Oregon, and Hawaii have a standard recommending that 

individuals have enough food and water to support themselves for 14 days. These efforts 

could serve as a model for federal and state preparedness resources, campaigns, and 

training.

o The idea of individual preparedness is not a new concept. Civil defense, an older term used 

to elevate a level of individual preparedness and activate communities, used to be more 

widely accepted.

o FEMA offers a number of tools, resources, and guidance on emergency preparedness, 

including recent efforts focused on better financial preparedness for disasters, and work 
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with interagency partners on activity books and courses to educate students on emergency 

preparedness.

• See Appendix F for more information on individual and community emergency preparedness efforts. 

Ongoing Initiatives

• FEMA’s 2018-2022 Strategic Plan: The Strategic Plan is a framework for supporting the United 

States before, during, and after disasters, and has three Strategic Goals aimed at mobilizing a whole 

community approach to disaster response to build a culture of preparedness, readying the nation 

for catastrophic disasters, and reducing FEMA’s complexity.5

o Strategic Goal 1: Build a Culture of Preparedness includes objectives to incentivize 

investments that reduce risk, including pre-disaster mitigation; closing the insurance gap; 

helping people prepare for disasters; and better learn from past disasters, improve 

continuously, and innovate.

Recommendation 4 

Design and support a portfolio of incentives that provide financial support or remove 

financial and regulatory barriers to help companies, nongovernmental organizations,

and state, local, tribal, and territorial governments implement the recommendations 

included in this report. 

Develop incentives at the federal level and provide guidance to help state and local legislators, regulators, 

and insurers to provide incentives that encourage public and private investment in resilience.

A. The national design basis provides the criteria needed to justify the actions or 

necessary funding. Federal agencies responsible for implementing the recommendations must 

determine what incentives make sense to drive action, and examine whether they have the 

authority and funding available to do so. 

B. For the Electricity Subsector: 

i. The Secretary of Energy should seek to identify major incentives that could quickly have 

impact, forming a framework of incentives that can be added to over time, and taking into 

account the different ownership structures in the Electricity Subsector (e.g., investor-owned 

utilities, cooperatives, public power utilities) and that some may need more direct financial 

support. 

ii. The Federal Energy Regulatory Commission (FERC) should implement cost recovery and 

return on equity incentives for investments in hardening the bulk power system (BPS). 

iii. The Secretary of Energy should work with Congress to provide incentives and technical 

assistance for state public utility commissions to evaluate cost recovery for resilience 

investments or provide cost recovery incentives at the retail or distribution level. 

iv. The Secretary of Energy should work with Congress to provide liability protection and other 

incentives set forth in the recommendations where the government lacks authority. 

 

5 FEMA, 2018-2022 Strategic Plan, 2018. 
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C. Incentives that should be considered by agencies include: 

i. Regulatory compliance waivers during events

ii. Matching funds for state grants or other investments 

iii. Mitigation funding (e.g., grant reform for hardening systems) 

iv. Streamlined permitting for investments or actions included in the report 

v. Tax credits for making investments to meet the federal resilience design basis 

vi. Engaging the insurance industry to discuss insurance rate structures that value investments 

in resilience 

vii. Funding for pilot programs to test implementation of new measures at the state level

Lead: Secretary of Treasury

Support: Secretaries of the relevant Sector-Specific Agencies (Primary), Federal Energy Regulatory 

Commission, and other federal agencies as appropriate 

Supporting Findings

• All levels of government need a more comprehensive understanding of federal and state 

investments in order to better target funding to help manage the growing costs of catastrophic 

events. With the increasing severity and frequency of natural disasters, policymakers are looking for 

ways to control costs by investing in mitigation activities—actions that reduce risk to lives and

property—before a disaster happens.

• The federal government and states can support the development of consistent resilience design 

standards, understanding that regional and state and local circumstances may warrant different 

levels or kinds of resilience. 

o The NRMC’s efforts to prioritize functions that must remain operational during disasters 

could help identify and prioritize the investments needed to sustain those 

services/functions during a catastrophic power outage. 

• Consistent resilience design standards can make it easier for Public Utility Commissions (PUCs) and 

regulators to adjust rates for owners and operators by providing them with the guidance necessary 

to understand what the reasonable risk costs and tradeoffs are to support resilience investments.

• The federal government could support additional incentives or tax breaks to the operators, and/or 

the individual commercial or residential users, to encourage participation in specific resiliency 

projects. Other incentives include: 

o Regulatory compliance waivers during events

o Provide federal matching funds to state-run programs 

o Provide funding for mitigation ahead of a disaster (e.g., grant reform and supporting the 

DOE’s strategic transformer reserve)

• As we have recommended in previous studies, outcome-based market incentives—focused on the 

desired end-state rather than meeting minimum standards—can encourage large-scale 

infrastructure upgrades, directing company resources toward exceptional resilience improvements 

rather than demonstrated compliance with minimum standards.

o Outcome-based requirements give companies the flexibility to best achieve or exceed 

objectives, while allowing for variations in company structure, size, and resources.
16

• There should be an emphasis on deliberate planning, because intentional investment in 

infrastructure can mitigate the expense of recovery ($1 spend on mitigation can create $6 in 

savings6

). 

• In 2017, DOE and the National Association of Regulatory Utility Commissioners (NARUC) released a 

cybersecurity primer for regulatory utility commissions with best practices, access to industry and 

national standards, and other information.7

• During a grid emergency or a catastrophic power outage, utilities need to be able to reduce load or 

ensure certain areas have power. This will be crucial for national security, but will create haves and 

have nots. Liability protections need to be put in place for grid owners and operators to do this 

during an emergency because the Federal Power Act does not provide liability protection. 

o Congress should legislate the expansion of liability protections for grid owners and 

operators.

• The power grid is a prime target for attack by nation states, and it is not fair for ratepayers to bear 

the full burden for this national security function. 

 

6 National Institute of Building Sciences, Natural Hazard Mitigation Saves: 2017 Interim Report, 2017. 7 Karen Evans, DOE Modernization: The Office of Cybersecurity, Energy Security, and Emergency Response, Hearing before the Committee on Energy 

& Commerce, Subcommittee on Energy, 2018. 
17

Identify cascading failures impacting key sectors, especially natural gas supply and communications, to 

ensure their availability to aid power restoration, and identify actions to improve resilience to a 

catastrophic power outage. There is a lack of understanding of the cascading, cross-sector 

interdependencies among critical infrastructure and what that means for prioritizing backup generation and 

other limited resources to maintain services and functions during a long-term, widespread catastrophic 

power outage. The recommendations in this section are aimed at building a better understanding of how 

different infrastructure interacts with each other, particularly during a failure, to inform the steps needed to 

prepare for a catastrophic power outage. 

Recommendation 5 

Conduct a series of regional catastrophic power outage exercises that identify the 

second- and third-order cascading failures of an outage over time, as backup 

resources and mutual aid agreements are exhausted, and examine cross-sector 

supply chain and cyber risks that could delay re-energizing the grid. 

Include all cross-sector partners, including critical infrastructure owners and operators (e.g., natural gas 

supply, water and wastewater, transportation, communications, finance, food and agriculture, public 

health); SLTT government officials; NGOs; and transmission operators and power utilities. Conduct exercises 

in the existing bulk power system regions—as coordinated by Regional Transmission Organizations (RTOs), 

Independent System Operators (ISOs), and North American Electric Reliability Corporation (NERC) Regional 

Reliability Coordinators—to provide a realistic view of how electricity failures would occur, and the 

cross-sector and cross-jurisdictional issues that would result. In addition, employ the convening power of 

the federal government to guide and support planning and exercises for all U.S. geographic areas, 

particularly islands and territories. 

A. Use results of the exercises to develop guidance on how RTOs/ISOs and Reliability 

Coordinators should conduct blackstart exercises and response/recovery planning with their 

region’s power generation plant owners, transmission owners, and fuel providers to ensure the 

sufficiency of blackstart resources and identify risks specific to catastrophic power outages. 

B. Review and build upon lessons learned from GridEx, the National Level Exercise, and 

other relevant exercises, including blackstart drills and DOE’s Liberty Eclipse, taking into account 

the need for exercises to simulate the dynamic and compromised circumstances that will be 

experienced during a catastrophic power outage. 

C. Synthesize the analysis on cross-sector failures over the last 10 years from after-action 

reports and other documents to identify and recommend best practices, and to better understand 

how infrastructure failures cascade. 

D. Employ the convening power of the federal government to guide and support 

collaborative cross-sector engagement to improve the shared understanding of cascading 

interdependencies and mitigation paths and processes. This should involve engaging sectors not 

previously involved in exercises. 
18

i. Engage cross-sector entities under the Critical Infrastructure Partnership Advisory Council 

(CIPAC) to encourage more collaboration across government and industry in implementing 

the recommendations from these exercises. 

Lead: Secretary of Energy

Support: Federal Emergency Management Agency (Primary), North American Electric Reliability 

Corporation (Primary), Department of Homeland Security, and Federal Energy Regulatory 

Commission 

Supporting Findings

• There are a number of existing exercises that consider large-scale power outages, but they have not 

matured to engage all necessary stakeholders, from local and community leaders to cross-sector 

representatives; and are unable to answer exactly who will be making decisions and what actions 

the federal government will take. 

o Centralized tabletop exercises may have challenges with engaging a large number of 

stakeholders, but distributed play aspects could provide greater opportunities to broaden 

participation to state and local governments and other sectors. For example, some states, 

such as Wisconsin and South Carolina, used the distributed play from GridEx as their major 

state disaster planning exercise. 

• RTOs/ISOs and reliability coordinators have existing blackstart plans that are routinely exercised and 

built upon, but there is a desire for the government to be more involved. There is some 

inconsistency in how blackstart plans are exercised with key stakeholders, including fuel suppliers 

and state and local government. 

• There is no economic backstop to prop up companies that lose a large percentage of their 

customers during a catastrophic power outage. There is also no nationwide backstop to prop up the 

national economy if the power is out for so long that financial institutions are unable to operate and 

companies cannot access capital.

• Emergency managers at the state, county, and local levels have existing relationships with owners 

and operators of critical infrastructure in their jurisdictions, and should be empowered and 

supported to take on more responsibility during a catastrophic power outage. 

• See Appendix E for more information on cross-sector exercises.

Ongoing Initiatives

• Cross-sector dependency models: To understand the impacts of a catastrophic power outage, 

modeling of the critical U.S. infrastructure—electricity, natural gas, and other dependent sectors—is 

needed to identify vulnerabilities and define solution paths. Current efforts include: 

o DOE is working with its partners to develop a North American Resiliency Model. 

o The Electric Infrastructure Security (EIS) Council is working on a Global Infrastructure 

Network Optimization Model (GINOM). 

• Tri-Sector Executive Working Group: The NIAC had previously recommended the formation of a 

strategic infrastructure group—made up of senior executives from the Electricity Subsector and

Financial Services and Communications Sectors—who can direct priorities and marshal resources. 

The Tri-Sector Executive Working Group is being chartered under the CIPAC. The newly formed 

NRMC intends to work closely with the group for sustained cross-sector engagement. 
19

Recommendation 6 

Ensure that all critical natural gas transmission pipeline infrastructure has the 

appropriate standards, design, and practices to continue service during a

catastrophic power outage and maintain rapid availability to support blackstart 

generation. 

Establish programs—working with the pipeline, electric power, and communications industries—to ensure 

secure pipeline operations and resilience by examining overall interconnectedness and mutual 

interdependencies. 

A. These programs may include voluntary, industry-led efforts, mandatory standards, or a 

combination of these approaches. It may require using existing legal authorities or, after 

consultation with industry, developing new legal authorities. 

B. Establish guidance that encourages power generation and transmission owners and 

operators to conduct blackstart exercises with their natural gas providers to identify and 

plan for scenarios where fuel supply issues may impede blackstart capabilities and delay 

re-generation of the grid. 

Lead: Secretary of Energy 

Support: Department of Transportation (Primary), Transportation Security Administration, North 

American Electric Reliability Corporation, Federal Energy Regulatory Commission

Supporting Findings

• The electric system has a growing dependence on the natural gas pipeline system to assure 

operation, resilience, and recovery from outages. 

o The Electricity Subsector is becoming more reliant upon natural gas as a fuel source; from 

2002 to 2016, the share of electricity generated by gas-fired units increased from 18 percent 

to about 34 percent while the share generated by coal fell from about 50 percent to about 

30 percent.8

• The construction of natural gas pipelines is driven by the market and demand. Pipelines are built to 

meet firm capacity when there is a willingness and ability of customers (i.e., shippers) to financially 

commit to the gas that would be provided.

o Limited pipeline capacity in a particular region can be attributed to factors such as 

environmental regulations hindering construction and/or residents who do not want 

pipelines in their communities. Also, there may be a general lack of incentive(s) among the 

generator community to contract for firm service. 

• There are modest steps being taken to address pipeline security, including recently updated and 

expanded Transportation Security Administration (TSA) voluntary guidelines, but these steps need 

to be expanded. 

o The NERC has offered a set of recommendations on opportunities for gas-electric 

coordination, many of which might be supported by data to facilitate broader assessments 

of fuel resilience and collaborative mitigation measures.

 

8 DOE, Staff Report to the Secretary on Electricity Markets and Reliability, 2017.
20

• See Appendix E for more information on the Oil and Natural Gas Subsector. 

Ongoing Initiatives

• Pipeline Cybersecurity Initiative: The CISA Director, TSA Administrator, and CESER Assistant 

Secretary met in October 2018 to identify ways to collaborate with industry partners to enhance 

and improve pipeline cyber and physical security. 

Recommendation 7 

Develop or support a flexible, adaptable emergency communications system that 

all sectors can interoperably use, that is self-powered, and is reasonably protected 

against all hazards to support critical service restoration and connect 

infrastructure owners and operators, emergency responders, and government 

leaders. 

A. A portfolio of communications capabilities must be put in place to ensure that the private 

sector, federal and SLTT governments, and others are able to communicate despite the cause of an 

outage.

i. Draw on DOD capabilities and technical expertise on survivable communications during a 

disaster. 

Lead: Secretary of Homeland Security

Support: Department of Defense (Primary), Department of Energy, Federal Communications 

Commission

Supporting Findings

• Restoration and recovery are next to impossible without working communications systems. Existing 

plans and exercises rely on the ability to coordinate response via voice or data communications 

systems, which are likely to be unavailable or degraded during a catastrophic power outage. 

o Most companies have internal emergency communications and/or plans for restoration in a 

degraded state or blackstart. However, cross-sector coordination and support requires 

broader telecommunications hardening. 

• Backup power generation is a commonly accepted emergency response standard, but backup (i.e., 

diverse or redundant) communication capabilities are generally not standard. 

• The electric industry has been examining historical methods to enhance resilience. Use of amateur 

or single-sideband radios for communications and manual management of electric grid operations 

by frequency are being trialed. 

• Communications systems, including information technology (IT), need to be robust and capable of 

operating even in a degraded state to provide situational awareness and allow for coordination and 

information-sharing among federal government authorities, SLTT government, owners and 

operators, and communities. 

o Emergency communications must have backup power and be deployable to all 

infrastructure and critical supply chains. 
21

• Backup communication devices are available—such as satellite phones—but they are typically 

limited in number and are often not maintained or protected from all hazards. People also may not 

know how to use them or have the correct numbers for the people they need to reach. The 

bandwidth capacity and number of devices for backup communications such as satellite phones is 

not adequate to fully support the coordination of recovery and restoration efforts during an event 

of this scale. 

o All communications systems are vulnerable to damage or attack, necessitating a variety of

possible communication methods. To have resilient communications requires being 

prepared for multiple potential outcomes. 

o There needs to be a prioritized method for communications in a degraded state when 

communication goes out across multiple sectors.

• The level of network assuredness anticipated to meet these needs can be provided in whole, or in 

part, by commercial communication providers. A number of federal departments and agencies have 

already addressed their own need for high-assurance communications to support their essential 

missions. 

• DHS has previously contracted comparable networks for critical entities to use under similar 

circumstances (e.g., the Critical Infrastructure Warning Information Network (CWIN)). The 

approaches used by these agencies, as well as DHS’s past experience, may provide a template to 

expedite developing the requirements for implementing network capabilities resistant to a wide 

range of catastrophic scenarios. 

• Survivable communications are the lynchpin for responding to this type of event and restoring 

electricity (e.g., ability for power companies to communicate with each other and the government). 

o The Pentagon has done a tremendous amount of work on survivable communications that 

can provide the minimum level of functionality needed. 

o Supply chain risk management will also be important to ensuring communications systems 

are survivable and resistant to takeover. 

o FEMA, DOD, and DOE can all provide technical assistance to meet the minimum level of 

requirements needed. 

• See Appendix F for more information on the Communications Sector. 

Ongoing Initiatives

• The Electricity Subsector Coordinating Council (ESCC) Resilient Communications Working Group

has identified the need to update, modernize, and move some of the underlying systems out of 

private networks partially because real-time coordination across multiple sectors makes voice and 

data telecommunications critical for operation of the grid. The ESCC has also recommended that 

some form of backup communications capability to restore the grid after a major disaster needs to 

be created. 

o The ESCC has created a policy principle statement supporting emergency communications 

to validate and formalize the current work being done with the Communications Sector. 

• The EIS Council is working on Black Sky Emergency Communications and Coordination System 

(BSX)—an interoperable, secure system that can incorporate a range of communication 

technologies to support grid re-start activities.9

 

9 EIS Council, “Black Sky Emergency Communication & Coordination System: BSX,” 2018. 
22

Moving Forward: A Call to Action 

A catastrophic power outage could paralyze entire regions with grave consequences for national security, 

economic security, and public health and safety. The magnitude of this threat requires the federal 

government to lead in every way possible to: 

• Establish and execute clearly understood authorities

• Maintain a high-priority mission for catastrophic power outages

• Provide steadfast guidance and incentives for action

• Deliver resources, including dollars, expertise, and decision-making capabilities

To do so requires the federal government serve as convener and lead collaborator for critical infrastructure 

owners and operators and stakeholders across all levels of government. Strong and effective public-private 

collaboration will be crucial. 

Throughout this study, we have learned about ongoing initiatives, such as the work the EIS Council has done 

developing materials and playbooks on black sky hazards, the current efforts by FEMA to build individual 

preparedness and incorporate lessons learned into the nation’s emergency response plans, and the work of 

CISA to build cross-sector collaboration, along with many other efforts across government and industry. This 

work is important and is helping to drive action. It should continue to be supported and advanced. 

We believe our recommendations build on this ongoing work and provide a path forward for enhancing the 

nation’s capabilities to respond to and recover from these never-before-experienced events. 

Given the importance of this issue and the number of ongoing efforts, we ask the NSC—working with the 

lead agencies identified—to provide a status update to the NIAC within nine months of the report’s approval 

on how our recommendations are being implemented, progress being made on ongoing initiatives, or any 

significant barriers to implementation. 
23

Appendix A: Acknowledgements

Working Group Members

Constance H. Lau (Co-Chair), President and CEO, 

Hawaiian Electric Industries, Inc. (NIAC Chair)

William Fehrman (Co-Chair), President and CEO, 

Berkshire Hathaway Energy

Jan Allman, President, CEO, and General 

Manager, Marinette Marine Corporation* 

Dr. Georges Benjamin, Executive Director, 

American Public Health Association

William Terry Boston, Former CEO, PJM 

Interconnection* 

Benjamin Fowke, Chairman, President, and CEO, 

Xcel Energy* 

George Hawkins, Former CEO and General 

Manager, District of Columbia Water and Sewer 

Authority*

Joan McDonald, Director of Operations, 

Westchester County, New York* 

Beverly Scott, Ph.D., CEO, Beverly Scott 

Associates, LLC; former General Manager, 

Massachusetts Bay Transportation and Rail, and 

Transit Administrator for the Commonwealth of 

Massachusetts (NIAC Vice Chair)* 

Michael Wallace, Former Vice Chairman and 

COO, Constellation Energy

* Denotes Working Group members who served 

as part of the study scoping effort

Study Group Members

Scott Seu (Co-Chair), Senior Vice President, Public 

Affairs, Hawaiian Electric Company

Peter Grandgeorge (Co-Chair), National Security 

and Resiliency Programs Advisor, MidAmerican 

Energy – Berkshire Hathaway Energy

Scott Aaronson, Vice President, Security and 

Preparedness, Edison Electric Institute (EEI)

Theodore Basta, Chief Executive, TJB Transit 

Consultant Services 

Kathryn Condello, Director, National Security and 

Emergency Preparedness, CenturyLink

Randy Crissman, Senior Reliability and Resilience 

Specialist, Utility Operations, New York Power 

Authority (NYPA) 

Kimberly Denbow, Senior Director of Security, 

Operations and Engineering Services, American 

Gas Association 

Michele Guido, Business Assurance Principal, 

Southern Company

Suzanne Lemieux, Manager, Midstream and 

Industry Operations, American Petroleum 

Institute

Nathaniel T. Millsap Jr., Director, Industrial 

Security and Technology, Marinette Marine 

Corporation

Frank Prager, Vice President, Policy and Federal 

Affairs, Xcel Energy 

Jonathan Reeves, Americas, Resiliency Lead, 

Facebook; former Chief, Office of Emergency 

Management, District of Columbia Water and 

Sewer Authority

Saul Rojas, Vice President, Technical Compliance, 

NYPA
24

Working Group Interviewees

Robert Blue, Executive Vice President and 

President and CEO, Power Delivery Group, 

Dominion Energy

Jeffrey Byard, Associate Administrator, Office of 

Response and Recovery (ORR), Federal 

Emergency Management Agency (FEMA)

Carlos J. Castillo, Associate Administrator, 

Resilience, FEMA 

Stephen A. Cauffman, Research Engineer, 

Community Resilience Program, National Institute 

of Standards and Technology (NIST)

Christina Cody, Director, Energy Sector Resilience, 

National Security Council (NSC)

Jimmie Collins, Senior Advisor to U.S. Indo-Pacific 

Command (USINDOPACOM), Department of 

Energy (DOE) 

Lt. Gen. Reynold Hoover, Deputy Commander, 

U.S. Northern Command (NORTHCOM) 

Maj. Gen. Donald E. Jackson Jr., Deputy Inspector 

General, Office of the Inspector General, U.S. 

Army; former Deputy Commanding General, Civil 

and Emergency Operations, U.S. Army Corps of 

Engineers (USACE)

Chris Krebs, Director, Cybersecurity and 

Infrastructure Security Agency (CISA), U.S. 

Department of Homeland Security (DHS)

Bob Kolasky, Director, National Risk Management 

Center (NRMC), DHS 

Mark Lauby, Senior Vice President and Chief 

Reliability Officer, North American Electric 

Reliability Corporation (NERC) 

John McAvoy, Chairman, President, and CEO, 

Consolidated Edison, Inc.

Arthur Ray, Director, Critical Infrastructure Policy,

NSC

Louis Renjel, Vice President, Federal Government 

Affairs and Strategic Policy, Duke Energy

James Robb, President and CEO, NERC

Lt. Col. Brad Smith, Homeland Defense, Defense 

Support to Civil Authorities, USINDOPACOM 

Mark Stephens, City Manager, New Bern, North 

Carolina 

Paul Stockton, Ph.D., Managing Director, 

Sonecon LLC; former Assistant Secretary of 

Defense for Homeland Defense and Security 

Affairs

James P. Torgerson, CEO, Avangrid, Inc. 

Bruce Walker, Assistant Secretary, Office of 

Electricity (OE), DOE

Study Group Interviewees

Keith Adams, Vice Chair, National Voluntary 

Organizations Active in Disaster (NVOAD); Chair of 

the New Jersey VOAD

Allen Bintz, Principal Solutions Architect, Strategic 

Government, CenturyLink 

Michael Bryson, Vice President, Operations, PJM 

Interconnection LLC (PJM)

Janice K. Devers, Director, Tariffs and Regulatory 

Affairs, Algonquin Gas Transmission, LLC

Antonio L. Fernández, Director, Latinos for 

Healthcare Equity

Dr. Eric Goralnick, Medical Director, Emergency 

Preparedness, Brigham and Women’s Hospital 

(BWH)
25

Brian Harrell, Former Managing Director, 

Enterprise Protective Services, Duke Energy 

Corporation

Trevor Hines, Lead of Operations Information and 

Communications, Midcontinent Independent 

System Operator (MISO)

Jesse Levin, Founder, Tactivate

Dave McCurdy, President and CEO, American Gas 

Association (AGA)

James Merlo, Ph.D., Vice President and Director 

of Reliability Risk Management, NERC

Manuel Miranda, Senior Vice President of Power 

Delivery, Florida Power & Light Company (FPL)

Jay Montgomery, Vice President, Corporate 

Security and Business Continuity, Kinder Morgan 

Energy Partners; Chair, Oil and Natural Gas Sector 

Coordinating Council (SCC)

Chris Oberg, Principal Engineer, Network, Verizon 

Wireless; Chair, Communications Information 

Sharing and Analysis Center (ISAC)

David Owens, Chair, Transformation Advisory 

Council (TAC), Puerto Rico Electric Power 

Authority (PREPA)

Jeffrey Pillon, Director, Energy Assurance

Programs, National Association of State Energy 

Officials (NASEO)

Gil Quiniones, President and CEO, NYPA; Chair, 

Puerto Rico Energy Resiliency Working Group

Steve Rourke, Vice President, System Planning, 

ISO New England (ISO-NE)

Kris Ruud, Principal Advisor, Engineering and 

Real-Time Operations, MISO

Donald Santa Jr., President and CEO, Interstate 

Natural Gas Association of America (INGAA)

William Whaley, Vice President, U.S. Pipelines 

Gas Control, Enbridge Gas Distribution and Union 

Gas

Dena Wiggins, President and CEO, Natural Gas 

Supply Association (NGSA)

Le Xie, Ph.D., Associate Professor, Texas A&M 

University

Wesley Yeomans, Vice President, Operations, 

New York Independent System Operator (NYISO)

NIAC Scoping Effort Interviewees (Nov. 2017–June 2018) 

Scott Aaronson, Vice President, Security and 

Preparedness, EEI

Nick Akins, Chairman, President, and CEO, 

American Electric Power 

Charles R. Alexander, Director, Contingency 

Operations, USACE

William Ball, Executive Vice President and Chief 

Transmission Officer, Southern Company

Kathryn Condello, Director of National Security 

and Emergency Preparedness, CenturyLink

Joshua Dozor, Deputy Assistant Administrator, 

Response, FEMA

Maj. Gen. Donald Dunbar, Adjutant General of 

Wisconsin, Wisconsin National Guard

Greg Engle, Director, Bureau of Planning and 

Preparedness, Wisconsin Emergency 

Management

Doug Fears, Deputy Assistant to the President, 

Homeland Security and Counterterrorism Advisor, 

NSC

Mark Fleming, Director, Homeland Preparedness 

and Resilience Policy, NSC
26

Deborah Fulk, Senior Planner, Response 

Operations Division, FEMA Region V

Sean Griffin, Former Program Manager, 

Infrastructure Security and Energy Restoration, 

DOE

Patricia A. Hoffman, Principal Deputy Assistant 

Secretary, OE, DOE

Michael Isper, Office of Security Policy and 

Industry Engagement (OSPIE), Transportation 

Security Administration (TSA)

Kenneth Mercado, Senior Vice President, Electric 

Operations, CenterPoint Energy

Charles Phillips, Surface Transportation Division, 

TSA

Paul Preusse, Director, Response Operations 

Division, FEMA Region V

Gil Quiniones, President and CEO, NYPA; Chair, 

Puerto Rico Energy Resiliency Working Group

Avi Schnurr, CEO and President, Electric 

Infrastructure Security (EIS) Council

Paul Stockton, Ph.D., Managing Director, 

Sonecon LLC; former Assistant Secretary of 

Defense for Homeland Defense and Security 

Affairs

Gus Wulfkuhle, Operational Planner, Response 

Operations Division, FEMA Region V

Department of Homeland Security Study Support Resources

Ginger Norris, Designated Federal Officer (DFO), 

NIAC, DHS

Deirdre Gallop-Anderson, Alternate DFO, NIAC,

DHS

Beth Slaninka, Nexight Group, LLC

Lindsay Kishter, Nexight Group, LLC

Kate McClaskey, Nexight Group, LLC
27 

Appendix B: Study Methodology

The United States has experienced long-term power outages (typically defined as 72 hours or more), such as 

the 2003 Northeast Blackout (more than 50 million customers without power across the Midwest and 

Northeast for up to four days), Hurricane Katrina in 2005 (2.7 million customers without power across four 

states for 2-4 weeks), and Superstorm Sandy in 2012 (more than 8.5 million customers without power in 

20 states and the District of Columbia for about two weeks).10 More recently, the devastation in Puerto Rico 

following Hurricanes Irma and Maria gave us a glimpse at how a loss of power can cascade into other 

sectors affecting public health and safety and the economy. 

The nation has steadily improved its ability to prepare for and respond to events that are of relatively short 

duration and extent. Federal and state entities have identified and incorporated lessons learned from each 

of the events listed above. 

This study is not focused on long-term power outages we have experienced. The President’s National 

Infrastructure Advisory Council (NIAC) was challenged to move beyond what we as a nation have 

experienced and to imagine what would happen if these events stretched beyond days or weeks to months 

or years, if they affected large swaths of the country, and existing response capabilities were exhausted. 

This appendix outlines how the NIAC approached this tasking. 

Charge to the NIAC 

Given the interconnected nature of critical systems and networks, new broad-scale approaches are needed 

to adequately prepare for, respond to, and recover from catastrophic disasters that can create significant 

power outages with severe cascading impacts to multiple critical sectors. 

On May 21, 2018, the White House through the National Security Council (NSC), tasked the NIAC to build on 

insights gathered during a scoping effort to develop findings and actionable pragmatic recommendations 

that address how the public and private sectors can work together to further enhance and integrate critical 

infrastructure resilience with response and recovery actions to mitigate the risks posed by catastrophic 

power outages. Specifically, the NSC tasked the NIAC with addressing five questions:

1. What investments, including approaches to increase resilience and reliability, are needed in 

infrastructure systems and supply chains to minimize the duration, extent, and recovery time for 

long-duration, large-scale power outages? What are the roles of the private and public sectors in 

these investments? 

2. What critical factors are required to sustain national security; operations within the banking and 

finance, public health and medical, communications, transportation, and water sectors; and the 

integrity of the national and regional economies during efforts to restore electric power?

3. What is the Nation’s readiness to prioritize and coordinate resource sharing among federal, state, 

and private entities during catastrophic power outages that will mitigate cascading impacts across 

the lifeline functions?

4. To what extent are regional and national-level vulnerabilities to catastrophic power outages 

understood, given the diversity and complexity of North American electric generation, transmission, 

distribution, and storage configurations and markets?

 

10 FEMA, Power Outage Incident Annex, 2017. 
28 

5. Where does the Power Outage Incident Annex to the Response and Recovery Federal Interagency 

Operational Plans fit within the context of public-private preparedness activities?

Study Approach 

To complete this task, the NIAC formed a Working Group of 10 NIAC members that:

• Built on the NIAC Catastrophic Power Outage Scoping Study completed in June 2018. As part of 

the scoping effort, the Council was tasked to identify the gaps and challenges the nation’s 

infrastructure would face during a catastrophic outage. A Working Group of six NIAC members: 

o Interviewed 21 senior leaders and subject matter experts from federal and state 

government and industry. 

o Reviewed more than 350 resources, including laws, reports, articles, and prior studies.

o Considered three key pillars to frame the study scope: 

 The infrastructure investments and system hardening that could minimize outage 

severity. 

 The critical factors required to sustain public health and safety and the integrity of 

the national and regional economies during power restoration. 

 The nation’s readiness to prioritize and coordinate resource sharing among federal, 

state, and private entities during an outage of unprecedented scale.

o Identified 8 key areas of inquiry for in-depth examination in the full study. 

• Formed a Study Group of 13 subject matter experts to vet and validate the 8 key areas of inquiry

from the scoping effort. The Study Group: 

o Conducted interviews of 24 experts from federal and state government, industry, and 

academia. 

o Conducted research and reviewed more than 100 sources to identify capabilities that 

aligned with government and industry needs and existing capabilities. 

• Defined catastrophic power outages to frame interviews, research, and discussions to ensure clarity 

in how these events are different and that the recommendations would be actionable. (See 

Appendix C for more detail on this definition). 
29 

• Leveraged the wealth of existing information and built on the body of extensive work examining 

the nation’s readiness to prioritize and coordinate resource sharing among federal, state, and 

private entities during a catastrophic outage. 

• Conducted interviews with 20 senior leaders and experts in government and experts in the private 

sector. (See Appendix A for a list of interviewees and report contributors). 

• Conducted research and reviewed more than 250 different sources, including statutes, reports, 

studies, congressional testimony, articles, and prior NIAC studies. 
30 

Appendix C: Definitions to Frame the Study

There are a number of terms used by federal agencies and in the emergency management space that 

describe severe, long-lasting disasters. The Department of Defense (DOD) uses the term “complex 

catastrophes,”11 the Electric Infrastructure Security (EIS) Council identifies “black sky events,”12 the Federal 

Emergency Management Agency (FEMA) has defined “long-term power outage,”13 and the National 

Response Framework (NRF) describes “catastrophic incidents.”14

The NIAC is not replacing these definitions, but rather defined the focus of this study so it is clear how these 

events are different; and to provide the framing and context needed to understand and implement its 

recommendations.

Similarly, the NIAC has defined critical infrastructure resilience in the context of this study based on other 

uses and definitions. This appendix includes the NIAC’s definitions of these two terms and key inputs used to 

develop them. 

I. Catastrophic Power Outage Definition

As part of the scoping effort, the NIAC defined catastrophic power outages as events beyond modern 

experience that exhaust or exceed mutual aid capabilities. The NIAC built on that definition to provide 

additional detail and clarity: 

1. These are likely to be no-notice or limited-notice events, and potentially an act of war that would 

require a military response. These potential events could include: 

a. Sophisticated cyber-physical attack timed with a major natural disaster 

b. Repeated events in a short period of time with significant physical damage

c. Electromagnetic events, whether natural or manmade, which could result in severe physical 

damage 

2. Long-duration, lasting several weeks to months (at least 2 months, but more likely 6 months or 

more) due to physical destruction to equipment, such as transformers or transmission lines; or the 

severity of the event resulting in limited work force to repair damage, or inability to create or 

transport replacement parts. 

3. Affects a broad area of the nation covering multiple states or regions, impacting between 50 million 

and 75 million people,15 and threatening the viability of state and regional economies and local 

communities. 

4. Results in severe cascading impacts that force critical sectors—water and wastewater systems, 

communications, transportation, healthcare, financial services—to operate in a degraded state, due 

to back-up generators running out of fuel and fuel resupply hindered by limited transit options or 

being diverted to higher priorities. 

a. Many generators will also break down after they are forced to run beyond design limits 

during an event that stretches weeks and months. 

5. Exceeds or exhausts capabilities of existing mutual aid programs and emergency response plans. 

 

11 DOD, Memorandum: Definition of the Term Complex Catastrophe, 2013. 12 EIS Council, “Black Sky Hazards,” Webpage. 13 FEMA, Power Outage Incident Annex, 2017. 14 FEMA, National Response Framework, 2015. 15 U.S. Census Bureau, 2017.
31 

a. Current emergency response plans and frameworks rely on aid being provided from 

unaffected areas and the ability to identify and communicate needs. This is unlikely to be 

possible during these events.

b. The Electricity Subsector has an effective mutual aid program, but during an event of this 

scale utilities are unlikely to have surplus supplies or work force, and depending on the 

severity of the event it may be impractical or impossible to bring help in from unaffected 

areas of the nation. 

c. States are also unlikely to be able to assist others given limited resources and expected 

barriers both legal and physical for moving materials and work force. 

A. Inputs for Definition of Catastrophic Power Outage 

The NIAC reviewed how other entities defined similar events and they served as key inputs. It also examined 

scenarios such as those used in exercises, planning, or actual historical events. 

Federal Emergency Management Agency

FEMA sought to address the challenges to the federal government posed by long-term power outages in its 

2017 Power Outage Incident Annex to the Response and Recovery Federal Interagency Operational Plans

(POIA) guidance for federal agencies.16 FEMA defined a long-term power outage as one that:

• Extends to multiple states and/or FEMA regions and leaves millions of customers without power for 

an extended period;

• A significant part of the population needs prolonged mass care and emergency assistance; 

• A loss of critical lifeline functions (e.g., energy, water, communications, and transportation) creates 

risk to health, personal safety, national security, and economic viability; 

• Results in significant loss of service or functions in other critical infrastructure sectors; and 

• State, local, tribal, territorial (SLTT), or insular governments need sustained operational coordination 

to respond to the effects.17

In the POIA, FEMA identified several events in modern experience that fit its definition, including the 2003 

Northeast Blackout, Hurricane Katrina, and Superstorm Sandy. 

Electric Infrastructure Security Council

The EIS Council defines black sky events as a catastrophic event that severely disrupts the normal 

functioning of critical infrastructure in multiple regions for long durations.18

Department of Defense 

DOD uses the term complex catastrophe, meaning any natural or man-made incident including cyberspace 

attack, power grid failure, and terrorism, which results in cascading failures of multiple interdependencies, 

critical, life-sustaining infrastructure, population, environment, economy, public health, national morale, 

response efforts, and/or government functions.19

 

16 FEMA, Power Outage Incident Annex, 2017. 17 Ibid. 

18 EIS Council, “Black Sky Hazard,” Webpage. 

19 DOD, “Department of Defense Dictionary of Military and Associated Terms,” 2010. 
32 

National Response Framework

The NRF has defined a catastrophic incident as “any natural or manmade incident, including terrorism, that 

results in extraordinary levels of mass casualties, damage, or disruption severely affecting the population, 

infrastructure, environment, economy, national morale, or government functions.”20

II. Critical Infrastructure Resilience Definition

Since resilience is a commonly used term, it is important to clarify its use in this context. The Working Group 

built on definitions from prior NIAC studies, Presidential Policy Directive-21, and the Executive Office of the 

President. 

For this study, critical infrastructure resilience is defined as the ability to prepare for and adapt to changing 

conditions, and reduce the magnitude and/or duration of disruptive events by: 

• Building robust systems through design, redundancy, and hardening so that the systems can

operate even in a degraded state; and 

• Embedding agility and adaptability into infrastructure systems and cyber systems. This creates the 

ability to respond and recover through: 

a. Preparedness and contingency planning; 

b. Training, technology, supply chain management and diversity; and

c. Improved information sharing and situational awareness to prioritize critical assets and 

functions.21

A. Inputs for Definition of Critical Infrastructure Resilience 

The following sources and definitions were referenced to develop the definition of critical infrastructure 

resilience for this study. 

National Infrastructure Advisory Council

“Infrastructure resilience is the ability to reduce the magnitude and/or duration of disruptive events. The 

effectiveness of a resilient infrastructure or enterprise depends upon its ability to anticipate, absorb, adapt 

to, and/or rapidly recover from a potentially disruptive event.”22

• Absorptive capacity: is the ability of the system to endure a disruption without significant deviation 

from normal operating performance.

• Adaptive capacity: is the ability of the system to adapt to a shock to normal operating conditions. 

For example, the extra transformers that the U.S. electric power companies keep on store and share 

increases the ability of the grid to adapt quickly to regional power losses.

• Recoverability: is the ability of the system to recover quickly—and at low cost—from potentially 

disruptive events. 

Critical infrastructure resilience is characterized by three key features: robustness, resourcefulness, and 

rapid recovery. 

 

20 FEMA, National Response Framework, 2015. 21 NIAC, Critical Infrastructure Resilience: Final Report and Recommendations, 2009; NSTAC, Report to the President on Communications Resiliency, 

2011; The White House, Presidential Policy Directive 21, 2013. 22 NIAC, Critical Infrastructure Resilience: Final Report and Recommendations, 2009.
33 

Executive Office of the President

“The EOP (Executive Office of the President) proposed seven principles as critical success factors by which 

the task force could examine the resiliency of the network, including:

• Redundancy (multiplicity, spares) 

• Diversity (multiple approaches and suppliers)

• Agility (ability to shift)

• Adaptability (ability to adjust) 

• Prioritization (dedicated or shared resource) 

• Geography (diversity, proximity) 

• Hardening (ability to withstand direct force).”23

Presidential Policy Directive 21—Critical Infrastructure Security and Resilience

“The term resilience means the ability to prepare for and adapt to changing conditions and withstand and 

recover rapidly from disruptions. Resilience includes the ability to withstand and recover from deliberate 

attacks, accidents, or naturally occurring threats or incidents.”24

 

23 NSTAC, Report to the President on Communications Resiliency, 2011. 24 The White House, Presidential Policy Directive 21, 2013. 
34 

Appendix D: Government Authorities, Processes, and 

Roles

In the United States, the role of the federal government in disaster response is to “supplement the efforts 

and available resources of states and local governments, and disaster relief organizations in alleviating 

damage, loss, hardship, or suffering.”25 This “bottom-up” approach is a tried and true mechanism. The 

federal government is the only level of government with the authority and capability to cope with 

widespread events, because most catastrophic impacts span multiple states and municipalities.26

The Federal Emergency Management Agency (FEMA) noted in its 2017 Hurricane Season After-Action Report

that “no jurisdiction or federal agency has all the staff and resources it will need to respond to a 

catastrophic incident.”27 And in its 2018-2022 Strategic Plan, FEMA states that the agency “does not and 

cannot serve as the sole or primary responder.”28 The Agency’s practice is that emergency management 

strategies are most effective when they are “federally supported, state managed, and locally executed.”29

However, the concern is that when a catastrophic power outage or other complex disaster occurs, it has the 

potential to immediately overwhelm state and local capabilities. In this scenario, there is not an equivalent 

“top-down” approach or process where the federal government acts as the initial and primary source of aid 

that is understood and accepted by all parties.

This appendix provides an overview of existing federal authorities and processes during a disaster and how 

these interact with state, local, tribal, and territorial (SLTT) government and community roles. It also 

includes an overview of the roles of federal agencies, state and local government, and industry during 

emergencies. 

I. Federal Authorities and Processes 

Federal response to an event is guided by several frameworks and documents under the National 

Preparedness System (NPS), building off the National Preparedness Goal to establish “a secure and resilient 

nation with the capabilities required across the whole community to prevent, protect against, mitigate, 

respond to, and recover from the threats and hazards that pose the greatest risk.”30

A. National Preparedness System

The NPS was established under Presidential Policy Directive 8: National Preparedness (PPD-8), issued by 

President Obama in 2011.31 NPS is designed to help “ensure the Nation’s ability to prevent, respond to, 

recover from, and mitigate against natural disasters, acts of terrorism, and other man-made disasters.”32

NPS includes a National Planning Framework for each of five mission areas—prevention, protection, 

 

25 Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. 93-288. 26 Amy Lui, “Feds, States, Cities – The All of the Above Disaster Response,” Brookings, November 2, 2012. 27 FEMA, 2017 Hurricane Season FEMA After-Action Report, 2018. 28 FEMA, 2018-2022 Strategic Plan, 2018. 29 Ibid.

30 DHS, National Preparedness Goal, 2015. 31 DHS, “Presidential Policy Directive 8: National Preparedness,” March 30, 2011. 32 6 U.S. Code §§ 743-744. 
35 

mitigation, response, and recovery33—as well as Federal Interagency Operational Plans (FIOPs) and guidance 

for SLTT governments for coordinating national preparedness efforts.34

The graphic below provides a high-level view of the NPS and its five frameworks and supporting plans. 

Within the NPS, the National Response Framework (NRF) is the principal interagency response coordination 

structure for declared Stafford Act events and non-Stafford Act events35—presidentially declared events 

that initiate federal disaster assistance—providing guidance for immediate response to a disaster.36 The NRF 

outlines how the United States responds to disasters and emergencies of all sizes,37 indicates how federal 

agencies should interact with SLTT governments and the private sector, and specifies when federal 

authorities assume control of national response.38

The NRF establishes different Emergency Support Functions (ESFs) to organize the response capabilities of 

the federal government,39 by grouping federal agencies with relevant authorities, resources, and expertise, 

with an established coordinator, primary agency or agencies, and support agency relevant to the ESF.40 ESFs 

are applied through the National Response Coordination Center (NRCC)—a multiagency center that 

coordinates the overall federal support for major incidents and emergencies.41

 

33 Statement of Robert J. Fenton, Pacific Northwest Seismic Hazards: Planning and Preparing for the Next Disaster, Hearing before the House 

Committee on Transportation and Infrastructure, May 19, 2015. 

34 DHS, Section 2(e): Assessment of Electricity Disruption Incident Response Capabilities, 2018. 35 DHS, National Response Framework, 2008. 36 Jared T. Brown, et al., Congressional Primer on Responding to Major Disasters and Emergencies, Congressional Research Service, 2017. 37 DHS, National Response Framework, Second Edition, May 2013. 38 Richard Weitz, “Federalism and Domestic Disasters: Promoting a Balanced Approach,” Hudson Institute, 2006. 39 DHS, National Response Framework, Third Edition, June 2016. 40 Jared T. Brown, et al., Congressional Primer on Responding to Major Disasters and Emergencies, Congressional Research Service, 2017. 41 FEMA, “Fact Sheet: National Response Coordination Center,” July 2015. 
36 

The National Disaster Recovery Framework (NDRF) 

is a companion to the NRF and outlines the 

strategy and doctrine for how a whole community 

builds, sustains, and coordinates recovery. The 

NDRF provides recovery principles, roles and 

responsibilities at the respective levels of 

government, and a structure and process to assist 

short-and long-term recovery following a disaster 

event.42

The most successful and impactful response 

following an emergency is local, but local 

governments and community-level organizations 

are often not actively engaged in disaster response 

planning. This creates a disconnect between the 

federal government and local 

governments/communities.

43

FEMA is in the process of updating the NRF44 to 

emphasize stabilization of community lifelines and coordination across critical infrastructure sectors.45

FEMA has identified seven community lifelines that provide indispensable services to enable the continuous 

operation of critical business and government functions, and are critical to health, safety or economic 

security.

46 These lifelines include: 1) safety and security; 2) food, water, and shelter; 3) health and medical

services; 4) energy; 5) communications; 6) transportation; and 7) hazardous waste. 

The intention is that communities would identify what stabilization in each of these lifelines means for their 

community, and use those stabilization targets in outcome-based planning. The NRF update is expected to 

put an increased emphasis on the capabilities of the private sector, individuals, and volunteer and 

nongovernmental organizations (NGOs), with potential public review and comment in early 2019.

The NRF update will also include the creation of a new ESF #14 focused on cross-sector coordination. ESF 

#14 will serve as a way to bring in industry to help prioritize responses. ESF #14 will be used by the federal 

government for building, sustaining, and delivering response capabilities, including those necessary for 

sustaining and restoring critical infrastructure.47 “[This] would cement in doctrine and practice the 

public-private sector partnership that is essential to stabilization and unity of effort, and bring new capacity 

to whole community response efforts.”48

B. National Incident Management System

The 2003 Homeland Security Policy Directive 5 (HSPD-5),49 called on the Secretary of Homeland Security to 

develop a national incident management system to provide a consistent nationwide approach for federal

 

The National Cyber Incident Response Plan

The National Cyber Incident Response Plan (NCIRP) is 

the Cyber Annex to the FIOP that builds upon the 

National Planning Frameworks and the NPS. The NCIRP 

was developed to articulate the roles and 

responsibilities, capabilities, and coordinating structures 

that support how the United States responds to and 

recovers from significant cyber incidents posing risks to 

critical infrastructure. It is the primary framework for a 

national approach to dealing with cyber incidents, 

addressing the important role that the private sector 

and state and local governments, and multiple federal 

agencies play in responding to incidents, and how the 

actions of all fit together for an integrated response. 

The last iteration of the NCIRP was in 2016.

Source: NCIRP, 2016

42 DHS, National Disaster Recovery Framework, Second Edition, June 2016. 43 EIS Council, E-PRO Handbook III Cross-Sector Coordination and Communications in Black Sky Events, 2018. 44 DHS, National Response Framework, 2008. 45 FEMA, 2017 Hurricane Season FEMA After-Action Report, 2018. 46 FEMA, “National Response Framework Update: Overview Briefing,” October 24, 2018. 

47 EIS Council, E-PRO Handbook III Cross-Sector Coordination and Communications in Black Sky Events, 2018. 48 FEMA, 2017 Hurricane Season FEMA After-Action Report, 2018. 49 DHS, Homeland Security Presidential Directive 5, 2003. 
37 

and SLTT governments to work together to prepare for, prevent, respond to, and recover from domestic 

incidents, regardless of cause, size or complexity.50 In 2004, the Department of Homeland Security (DHS)

issued the National Incident Management System (NIMS) as a companion to the NRF, which incorporates 

the capabilities and resources of various governmental jurisdictions, incident management and emergency 

response disciplines, nongovernmental organizations, and the private-sector into a cohesive, coordinated, 

and seamless national framework for domestic incident response.51

C. Stafford Act

The Robert T. Stafford Disaster Relief and Emergency Assistance Act, better known as the Stafford Act, 

provides the legal and statutory authority governing federal response to events in the United States.52 The

Act provides the system currently used for requesting and obtaining a Presidential emergency or major 

disaster declaration, determining the conditions for obtaining assistance, and defining the type and scope of 

assistance available from the federal government.

53 An emergency is any occasion or instance in which 

federal assistance not exceeding $5 million is needed to supplement state and local efforts and 

capabilities.54 Any natural event causing damage of such severity that it is beyond the combined capabilities 

of state and local governments to respond is considered a major disaster.

55

Federal response under the Stafford Act is generally the same for territories and federally recognized tribal 

nations, though there may be unique differences. The federal government maintains a moral and legal trust 

responsibility toward tribal governments, which includes an obligation to protect tribal treaty rights, lands, 

assets, and resources, as well as a duty to carry out the mandates of tribal law.56 This means that “any 

federal agency with a role in emergency preparedness and response, such as [FEMA], is obligated to provide 

consultation opportunities to tribes in addition to the other services and resources available at the 

agency.”57 Similar to states, tribal governments are responsible for coordinating resources to address actual 

or potential incidents.58 In 2013, the Sandy Recovery Improvement Act amended the Stafford Act to include 

a provision to provide federally recognized tribal governments the option to request a Presidential 

emergency or major disaster declaration independent of a state, cutting down on response time.59

The same approach and process applies to territories. However, due to their remote locations, territories 

often face unique challenges in receiving assistance from outside the jurisdiction quickly and often request 

assistance from neighboring islands, other nearby countries, states, the private sector or NGO resources, or 

the federal government. Federal assistance is delivered in accordance with pertinent federal authorities.”60

The graphic below provides an overview of the multi-step process for receiving a federal emergency and 

major disaster declaration under the Stafford Act. 

 

50 The White House, “Homeland Security Presidential Directive/HSPD-5,” 2003. 51 FEMA, “NIMS Frequently Asked Questions,” Webpage. 52 Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. 93-288. 53 FEMA, A Guide to the Disaster Declaration Process and Federal Disaster Assistance, Webpage. 54 42 U.S.C. § 5122. 

55 Ibid. 

56 Cohen's Handbook of Federal Indian Law § 5.04[3]; Seminole Nation v. U.S., 316 U.S. 286, 296-97 (1942); U.S. v. Jicarilla Apache Nation, 131 S. Ct. 

2313, 2324-25 (2011). 57 The White House, Memorandum on Government-to-Government Relations With Native American Tribal Governments, Apr. 29, 1994; Aila Hoss, 

“Tribal Consultation: Selected Resources,” CDC, 2016. 58 FEMA, “IS-0230.d – Fundamentals of Emergency Management. Lesson 1: Emergency Management Overview,” Webpage. 59 Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. 93-288; Disaster Declaration Improvement Act, Report 115-99. 60 FEMA, “IS-0230.d – Fundamentals of Emergency Management. Lesson 1: Emergency Management Overview,” Webpage. 
38 
39 

D. Federal Financial Disaster Relief Assistance, Waivers, and Mitigation Funding

A complex spending relationship underlies federal disaster assistance in the United States.61 Federal 

financial assistance is generally only available after a Stafford Act declaration and after an event has 

occurred. Under the Disaster Relief Fund (DRF)—the primary funding source for Stafford Act declared 

disaster response and recovery62—there are three principal forms of federal financial assistance available 

through FEMA.63 Through these forms of assistance, FEMA can fund authorized federal disaster support 

activities as well as eligible SLTT actions.64

No single government source provides comprehensive information about state spending.65 A Government 

Accountability Office (GAO) study found that because the federal government and states do not know how 

much they spend on mitigation in total, they lack the information to accurately compare proactive 

investments with post-disaster response and recovery expenditures. The larger the natural disaster, the 

more likely all levels of government participate and spend significant amounts of money.66 But all levels of 

government need a more comprehensive understanding of federal and state investments to better target 

funding to help manage the growing costs of catastrophic events. With the increasing severity and 

frequency of natural disasters, policymakers are looking for ways to control costs by investing in mitigation 

activities—actions that reduce risk to lives and property—before a disaster happens.67

In April 2018, the U.S. House of Representatives passed components of the Disaster Recovery Reform Act

(DRRA) as part of the Federal Aviation Administration (FAA) Reauthorization Act of 2018.68 The DRRA would 

provide funding for hazard mitigation programs, as well as introduce new reforms to programs, which 

include:69

• Amend the Stafford Act to establish increased and fixed reimbursement rates to state and local 

governments for direct and indirect administrative costs associated with disaster recovery efforts. 

This includes no more than 15 percent for hazard mitigation and 12 percent for essential assistance, 

repair, restoration, replacement debris removal, and transportation assistance.

70

• Allow states the option to administer FEMA funding for direct temporary housing and permanent 

housing construction after a disaster. FEMA must fund 100 percent of the direct temporary housing 

costs. 

• Establish the National Public Infrastructure Pre-Disaster Mitigation Assistance Program, which would 

commit certain funding from the DRF to pre-disaster mitigation efforts. It would allocate 6 percent 

of the combined obligations estimated following a major disaster to mitigation assistance. 

• Require the FEMA administrator to develop a plan to streamline information collection processes 

for grant applications and make the process less burdensome and time consuming.

 

61 Foundation Center and the Center for Disaster Philanthropy, “Measuring the State of Disaster Philanthropy 2017,” Webpage. 62 Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. 93-288. 63 The Public Assistance program is authorized by Sections 403(a)(3)(A), 406, 407, 428, and 502(a)(5) of the Stafford Act; Jared T. Brown and Daniel J. 

Richardson, FEMA’s Public Assistance Grant Program: Background and Considerations for Congress, 2015; Bruce R. Lindsay, The SBA Disaster Loan 

Program: Overview and Possible Issues for Congress, 2015; FEMA, “The Hazard Mitigation Assistance Grant Programs,” 2015. 64 Statement by Craig Fugate, The Federal Role in Disaster Recovery and Response, Hearing before the Committee on Appropriations’ Subcommittee 

on Homeland Security, October 12, 2011. 

65 GAO, “Budgeting for Disasters: Approaches to Budgeting for Disasters in Selected States,” 2015; National Association of State Budget Officers, 

“Budget Processes in the States,” 2015. 

66 UNISDR, “What Is Disaster Risk Reduction?” Webpage. 

67 Pew Charitable Trusts, “Natural Disaster Mitigation Spending is not Comprehensively Tracked,” September 2018. 68 FAA Reauthorization Act of 2018, H.R. 4, 115th Cong., 2nd Session, May 7, 2018. 69 FEMA, “Pre-Disaster Mitigation Grant Program,” Webpage. 70 Lucia Bragg, “House Passes Disaster Recovery Reform Act under FAA Reauthorization,” NCSL, April 27, 2018. 
40 

As the number of declared major disasters and emergencies increase,

71 and the amount of money needed 

for the DRF increases,72 the federal government bears escalating recovery costs. Insurance reform offers a 

promising way to encourage infrastructure upgrades that could promote resilience innovations and share 

disaster costs between the public and private sector. This is becoming more and more important because 

risk models indicate that the annual likelihood of severe weather causing at least $1 billion in insured losses 

in the U.S. is 92 percent.73

Federal financial assistance can also be in the form of waiver. Waiving statutes and regulations identified as 

impeding response and recovery efforts can help communities and companies make decisions without the 

threat of reprisal for noncompliance. For example, after Hurricane Maria hit Puerto Rico in 2017, the 

Environmental Protection Agency (EPA) granted a blanket waiver from ultra-low sulfur diesel requirements 

so that the territory could use power generators that use fuel with high sulfur content.74

II. Federal Agency Roles

As mentioned in the prior sections, various frameworks, authorities, and supporting documents outline how 

the federal government responds. Federal agencies also have roles in disaster response and recovery, most 

notably three agencies with a defined lead role in emergency preparedness and response or critical 

infrastructure protection. This section will provide an overview of the roles DHS, the Department of Energy 

(DOE), and Department of Defense (DOD) each play before, during, and after an event, and the role of 

Federal Energy Regulatory Commission (FERC), the federal agency that regulates the transmission and 

wholesale sale of electricity and natural gas. 

A. Department of Homeland Security

At its core, DHS secures the nation against evolving threats to safety and security through continuous risk 

assessments and adaptive strategies to effectively address them.75 Within this, DHS has five missions: 

1) preventing terrorism and enhancing security; 2) managing the country’s borders; 3) administering 

immigration laws; 4) securing cyberspace; and 5) providing the coordinated, comprehensive federal 

response in the event of a terrorist attack, natural disaster, or other large-scale emergency.

76 When events

such as natural disasters do occur and the federal government needs to provide assistance, DHS is the 

primary agency for coordinating federal assistance. This section highlights three key components under 

DHS: FEMA, the Cybersecurity and Infrastructure Security Agency (CISA), and the newly formed National 

Risk Management Center (NRMC). 

Federal Emergency Management Agency 

Within DHS, FEMA is the federal agency that coordinates the federal government’s role in preparing for, 

preventing, mitigating the effects of, responding to, and recovering from all domestic disasters, whether 

natural or manmade, including acts of terror.77 FEMA relies on the NRF and NDRF frameworks, which 

 

71 FEMA, “Incidents by Year,” Webpage.

72 Bruce R. Lindsay, FEMA’s Disaster Relief Fund: Overview and Selected Issues, Congressional Research Service, May 7, 2014. 73 Executive Office of the President of the United States, Standards and Finance to Support Community Resilience, 2016; Carolyn Kousky, et al., Does 

Federal Disaster Assistance Crowd Out Private Demand for Insurance? The Wharton School, 2013. 74 Subramanian, R., et al., “Air Quality in Puerto Rico in the Aftermath of Hurricane Maria: A Case Study on the Use of Lower Cost Air Quality 

Monitors,” ACS Earth and Space Chemistry, 2018. 75 DHS, “About DHS,” Webpage. 

76 Ibid.

77 Statement of Richard Campbell, Blackout! Are we Prepared to Manage the Aftermath of a Cyber-Attack or Other Failure of the Electrical Grid?

Hearing before the Committee on Transportation and Infrastructure, Subcommittee on Economic Development, Public Buildings, and Emergency 

Management, House of Representatives, April 11, 2016. 
41 

identify the subset of agencies best equipped to respond to a particular challenge, as well as the NIMS for a 

cohesive, coordinated incident response. 

FEMA has stated that the biggest lesson learned after the 2017 disasters is that the most effective strategies 

for emergency management are those that are federally supported, state managed, and locally executed. 

FEMA advocates a whole community approach to disaster management that includes individuals, families, 

communities, the private and nonprofit sectors, faith-based organizations, and local, state, tribal, territorial, 

insular areas, and other federal agencies.78 To that end, FEMA emphasizes that it is not the sole or primary 

responder to an event, therefore its role in emergency management is to coordinate federal resources and 

assistance to supplement SLTT capabilities.79 In that capacity, FEMA is responsible for building relationships 

with emergency management communities to encourage preparedness activities and mitigation 

investments before an event; manage requests for assistance during one; and coordinate and assign federal 

grant assistance with response and recovery after an event occurs.80

2018-2022 Strategic Plan 

FEMA issued the 2018-2022 Strategic Plan as a framework for supporting the United States before, during, 

and after disasters, with three Strategic Goals aimed at mobilizing a whole community approach to disaster 

response to build a culture of preparedness, readying the nation for catastrophic disasters, and reducing 

FEMA’s complexity.81

• Strategic Goal 1: Build a Culture of Preparedness includes objectives to incentivize investments that 

reduce risk, including pre-disaster mitigation; closing the insurance gap; helping people prepare for 

disasters; and better learn from past disasters, improve continuously, and innovate. 

• Strategic Goal 2: Ready the Nation for Catastrophic Disasters focuses on enhancing the nation’s 

collective readiness. This requires a scalable and capable national incident workforce that can adapt 

and deploy to a changing landscape of events, integrate stakeholders at all levels of the public and 

private sectors, and communicate and coordinate effectively in every situation. 

• Strategic Goal 3: Reduce the Complexity of FEMA promotes less complex processes to streamline 

FEMA and drive decision-making to reduce the administrative burdens that impede impacted 

individuals and communities from quickly receiving assistance.

Power Outage Incident Annex

In June 2017, FEMA released the Power Outage Incident Annex (POIA) to the Response and Recovery Federal 

Interagency Operational Plans: Managing the Cascading Impacts from a Long-Term Power Outage as 

guidance for federal agencies responsible for providing energy response and recovery support for a longterm power outage to SLTT, insular areas, NGOs, and the private sector.82 POIA states that “when a power 

outage is of such significance and scope that it is beyond the ability of utility companies to restore power in 

a timely manner, resulting in [SLTT] or insular area capabilities being insufficient to support the population, 

the federal government provides assistance to jurisdictional response and recovery capabilities.”83

The POIA is not an electricity restoration plan; it outlines the types of federal support available to critical 

infrastructure stakeholders when a power outage is of such significance and scope that it is beyond the 

 

78 FEMA, 2018-2022 Strategic Plan, 2018. 79 Ibid.

80 Ibid.

81 Ibid.

82 FEMA, Power Outage Incident Annex, 2017. 83 Ibid.
42 

ability of utility companies to restore power in a timely manner.84 It is a springboard, providing a framework 

to address interdependencies. The POIA describes a bifurcated command structure where DOE oversees the 

restoration of the power system (grid) and FEMA leads the federal consequence management effort.

However, actions in the POIA may be to provide support to local, state, tribal, territorial, and insular area 

governments or other federal agencies to address the ramifications of an incident.

FEMA is funding each FEMA Region to conduct long-duration power outage planning that will be tested, 

validated, and modified as needed. The goal is to coordinate emergency management and infrastructure 

protection into response and recovery plans so that each sector and/or region knows what their impacts 

may be and what support they might need from the federal government during or after an event. 

Cybersecurity and Infrastructure Security Agency 

Legislation was signed in November 2018 that 

renamed the National Protection and Programs 

Directorate (NPPD) to the Cybersecurity and 

Infrastructure Security Agency (CISA) to better 

reflect the agency’s role in both cyber and physical 

infrastructure security and resilience.

85 DHS 

Secretary Nielsen stated that the renaming “would... 

realign [the agency’s] structure to reflect the core 

cybersecurity and infrastructure resilience mission it 

exercises.”86

Similar to the former NPPD’s mission, CISA will work 

with public sector, private sector, and government 

partners to share information, build greater trust, 

and lead the national effort to protect and enhance 

the resilience of the country’s physical and cyber 

infrastructure.87 CISA partners with government and 

the private sector to protect and secure the people, 

places, spaces, data and networks that make the 

 

84 FEMA, Power Outage Incident Annex, 2017. 85 DHS, “Cybersecurity and Infrastructure Security Agency (CISA),” Webpage. 86 Tim Starks, “Senate could act on top DHS cybersecurity priority,” Politico, September 19, 2018. 87 DHS, “CISA Cyber + Security,” Webpage. 

National Cyber Security Strategy

In September 2018, the White House released the 

National Cyber Strategy, the first of its kind in 15 years.

The strategy highlights the growing threat that 

malicious cyber actors pose to U.S. national security and 

identifies cyber priorities structured around the National 

Security Strategy. The new strategy also calls for the 

administration to clarify the roles and responsibilities of 

federal agencies and the expectations of the private 

sector when it comes to cybersecurity risk management 

and incident response. DHS Secretary Nielsen stated the 

Strategy will “guide efforts by DHS to secure federal 

networks, protect critical infrastructure, and combat 

cybercrime.” 

Source: National Cyber Security Strategy, The White 

House 

FEMA Region V

FEMA Region V worked with its states (Illinois, Indiana, Michigan, Ohio, and Wisconsin) to review and understand 

their roles and responsibilities during a long-term power outage in conjunction with FEMA’s POIA.

Through the Region’s process to develop a POIA to provide supplemental hazard information to their All Hazards 

Plan, a series of workshops were conducted with local, state, and federal government representatives and private 

utilities. These workshops reviewed state energy plans, threat hazard identification and threat assessments, and 

sector interdependencies to understand the current capabilities so FEMA Region V could understand where there 

were needs from local and state partners and public and private utilities. 
43 

nation run,88 leading the U.S. government’s efforts to secure federal networks and critical infrastructure.89

The agency has also been spearheading the federal government’s election security efforts and coordinating

with state and local election offices on information sharing and cybersecurity best practices.90

CISA’s National Cybersecurity and Communications Integration Center (NCCIC) provides constant cyber 

situational awareness, defense, analysis, and incident response capabilities to the federal government, SLTT 

governments, and the private sector.91 CISA also includes the National Infrastructure Coordinating Council 

(NICC), which is the operations center that maintains situational awareness of the nation’s critical 

infrastructure for the federal government. The NICC serves as the coordination and information sharing hub 

to support coordination between DHS and owners and operators of critical infrastructure.92

National Risk Management Center 

In September 2018, DHS stood up a NRMC to focus on national strategic risks to critical infrastructure and 

serve as a convener for government and industry to work together, taking an all-hazards approach focused 

on critical functions.93 One of the NRMC’s goals is to be a place to coordinate on long-term cybersecurity 

and infrastructure security risk management, serving as the operational layer to develop strategic plans and 

take a unified approach to risks.94

Defining national critical functions produced by critical infrastructure that could cause systemic risk will also 

be a major undertaking by the NRMC. Defining these national critical functions can identify and locate 

interdependencies and concentrated dependencies that can determine what needs to be prioritized for 

restoration. 

The NRMC is building on prior NIAC recommendations, which called for an operational task force made up 

of senior executives from government and the Electricity Subsector and Financial Services and 

Communications Sectors, who can direct priorities and marshal resources.

95 As such, the NRMC is in the 

process of standing up a Tri-Sector Working Group made up of senior executives from the three sectors, 

which will be leveraged as a steering group for NRMC. 

Through the Critical Infrastructure Partnership Advisory Council (CIPAC), DHS in partnership with the 

Information Technology Sector Coordinating Council (IT SCC) and Communications Sector Coordinating 

Council (CSCC), has established the Information and Communications Technology (ICT) Supply Chain Risk 

Management Task Force within the NRMC. The Task Force is intended to focus on potential near- and 

 

88 DHS, “CISA Cyber + Security,” Webpage. 89 Zaid Shoorbajee, “DHS’s top cyber office is about to get a name that reflects its office,” CyberScoop, October 4, 2018. 

90 Ibid.

91 DHS, “What does CISA do?” Webpage.

92 DHS, “National Infrastructure Coordinating Council,” Last updated August 14, 2018. 93 DHS, “DHS National Risk Management Center,” Fact Sheet, 2018. 

94 Ibid. 

95 NIAC, Securing Cyber Assets: Addressing Urgent Cyber Threats to Critical Infrastructure, 2017.
44 

long-term solutions to manage strategic risks through policy initiatives and opportunities for innovative 

public-private partnership.

96

B. Department of Energy 

DOE is responsible for coordinating the Energy Sector’s emergency preparedness requirements—using 

processes and structures unique to the Energy Sector—as the lead for restoration and sector-specific lead 

agency for grid security. 

Emergency Authorities

Under the Fixing America’s Surface Transportation (FAST) Act,97 a federal law aimed at providing long-term 

funding for surface transportation infrastructure, the Secretary of Energy has “broad and nearly unilateral 

authority over critical electric infrastructure to protect system reliability in emergency situations.”98 Under 

the FAST Act, the Secretary of Energy has the authority, upon the declaration of a grid security emergency 

by the President, to issue emergency orders that—in his or her judgement—are necessary to protect or 

restore the reliability of critical electric infrastructure or defense critical electric infrastructure during the 

grid security emergency.

99 

Office of Cybersecurity, Energy Security, and Emergency Response 

The newly formed Office of Cybersecurity, Energy Security, and Emergency Response (CESER) works to 

ensure that the nation’s energy delivery system is secure, resilient, and reliable and develops new 

technologies to improve the infrastructure and the federal and state electricity policies and programs.100

Moving forward, CESER will focus on energy infrastructure security and support the expanded national 

security responsibility.

101 CESER will lead DOE’s emergency preparedness and coordinated response to 

disruptions to the Energy Sector, including physical and cyber-attacks, natural disasters, and man-made 

events.102 CESER will also spearhead efforts to secure the U.S. energy infrastructure against all hazards 

and mitigate the risk of energy disruption from cyber incidents and other emerging threats within the 

energy environment.103

 

Critical Infrastructure Partnership Advisory Council

DHS established CIPAC to facilitate interaction between governmental entities and representatives from the 

community of critical infrastructure owners and operators. Under CIPAC, members of the Government Coordinating 

Councils (GCCs) and Sector Coordinating Councils (SCCs) engage in discussions about joint critical infrastructure 

planning, coordination, implementation, and operational issues.

CIPAC provides the authority and structure for coordinating among government and critical infrastructure owners 

and operators; conducting operational activities related to critical infrastructure security and resilience measures, 

incident response, and recovery; and sharing threat, vulnerability, risk mitigation, business continuity information, 

and best practices along with lessons learned.

Source: FEMA, CIPAC FAQs

96 DHS, “ICT Supply Chain Task Force,” Press release, August 31, 2018. 97 Fixing America’s Surface Transportation (FAST) Act, Pub. L. 114–94. 98 Sylvia Bartell, “Transforming the Nation’s Electricity System. Part IV: Grid Security,” Husch Blackwell, January 16, 2017. 

99 DOE, “Grid Security Emergency Orders: Procedures for Issuance,” Federal Register, January 10, 2018.

100 Hunton Andrews Kurth, “Department of Energy Announces New Efforts in Energy Sector Cybersecurity,” May 30, 2018. 101 DOE, “Secretary of Energy Rick Perry Forms New Office of Cybersecurity, Energy Security, and Emergency Response,” February 14, 2018. 102 DOE, “CESER Mission,” Webpage. 103 Ibid. 
45 

C. Federal Energy Regulatory Commission 

FERC is the federal agency that regulates the transmission 

and wholesale sale of electricity and natural gas in 

interstate commerce and regulates the transportation of 

oil by pipeline in interstate commerce.104 While FERC does 

not have jurisdiction over generation facilities, or facilities 

used for local distribution or transmission in intrastate 

commerce,105 more than half of electric energy sales are 

subject to FERC’s rate jurisdiction. 

While FERC is responsible for ensuring adherence to 

mandatory reliability standards in industry, the North 

American Electric Reliability Corporation (NERC) develops 

those standards with input from the industry, submits 

them to FERC for approval, and then enforces the 

approved standards in the Energy Sector.106

FERC has also approved new mandatory reliability 

standards to bolster supply chain risk management 

protections for the nation’s bulk electric system. The new 

standards will augment current critical infrastructure 

protection standards to mitigate cybersecurity risks associated with the supply chain for grid-related cyber 

systems.107

D. Department of Defense

DOD is responsible for providing military forces and certain intelligence capabilities to deter war and to 

protect the security and national interests of the United States. As such, the Secretary of Defense may assist 

in the support of domestic infrastructure and essential restoration, or unprecedented events,108 through the 

mechanisms of the frameworks.109

While FEMA is the federal lead for national disaster response activities, DOD plays a supporting but 

important role in the national response system.110 As stated in the National Defense Strategy, while 

defending the homeland, DOD must also maintain the capacity to support civil authorities in times of 

national emergency such as in the wake of man-made and natural disasters.

111 In the event of crises within 

multiple states, or when many military units are deployed on overseas missions, affected regions may 

require assistance from DOD active-duty troops, the U.S. Coast Guard, and other federal assets.112

 

North American Electric Reliability Corporation 

As required by the Federal Power Act, FERC 

designated NERC—a nonprofit international 

regulatory authority responsible for reducing 

risks and ensuring reliability of the grid—as the 

Electric Reliability Organization (ERO) for North 

America. In this role, NERC oversees all 

interconnected power systems in the United 

States, Canada, and portions of Mexico and 

develops mandatory and enforceable reliability 

grid standards subject to FERC’s review and 

approval. As a designated ERO, NERC issues 

enforceable guidelines, essentially giving FERC 

the authority to oversee the reliability and 

resiliency of the U.S. grid, because FERC, 

through NERC, oversees the bulk power system. 

Source: FERC, FAQs 

104 California Independent System Operator Corporation v. FERC, 372 F.3d 395, 398-99 (D.C. Cir. 2004); Lawrence R. Greenfield, An Overview of the 

Federal Energy Regulatory Commission and Federal Regulation of Public Utilities in the United States, FERC, December 2010. 105 Garry Brown, et al., The Federal Power Act in the 21st Century: Summary Report of a Discussion Marking the 80th Anniversary of the Enactment of 

FPA Title II, Harvard Law School, September 1, 2015. 106 NERC, Milestones: NERC Reliability Standards, May 19, 2014. 107 Pamela Largue, “FERC announces new supply chain risk management standards,” Smart Energy International, October 22, 2018. 108 Jared T. Brown, et al., Congressional Primer on Responding to Major Disasters and Emergencies, Congressional Research Service, 2017. 109 DHS, National Response Framework, 2008. 110 Statement by Robert G. Salesses and Brigadier General Joseph E. Whitlock, Defense of Civil Authorities: A Vital Resource in the Nation’s Homeland 

Security Missions, Hearing before the Subcommittee on Emergency Preparedness, Response, and Communications of the Committee on Homeland 

Security, House of Representatives, June 10, 2015. 

111 DOD, National Defense Strategy, 2008. 112 Richard Weitz, “Federalism and Domestic Disasters: Promoting a Balanced Approach,” Hudson Institute, 2006. 
46 

The military responds under the authority under Title 32 and Title 10 of the U.S. Code, depending on the 

purpose and event.113 The president also has the authority to order the military to help plan for a disaster 

before it occurs, such as moving airplanes or prepositioning forces. While the president cannot order the 

military to execute or enforce federal law, that is not a blanket prohibition against deploying troops in a civil 

emergency.114

DOD has taken steps to improve its preparedness to better support civil authorities in effectively responding

to requests for assistance for power restoration during a catastrophe.115 The DOD complex catastrophe 

initiative is aimed at making defense support of civil authorities faster and more effective in delivering 

life-saving and life-sustaining requirements, which would enable DOD to bring all of its capabilities, from all 

components, to bear in support of civil authorities.116 The initiative is also directed at making improvements 

in the Defense Security Cooperation Agency (DSCA)—an agency that advances U.S. national security and 

foreign policy interests by building the capacity of foreign security forces to respond to shared 

challenges117—for regional planning and plans integration, force sourcing, training and exercises, and the 

role of military installations and Defense Agencies in emergency response operations.118

U.S. Northern Command 

The U.S. Northern Command (NORTHCOM) was established in 2002 to administer command and control of 

DOD homeland defense efforts and to coordinate defense support of civil authorities.119 NORTHCOM’s area 

of responsibility includes air, land, and sea approaches and encompasses the continental United States, 

Alaska, Canada, Mexico, and the surrounding water out to approximately 500 nautical miles. It also includes 

the Gulf of Mexico, the Straits of Florida, and portions of the Caribbean region that include the Bahamas, 

Puerto Rico, and the U.S. Virgin Islands.120

NORTHCOM plans, organizes, and executes homeland defense and civil support missions, but has few 

permanently assigned forces. Forces are assigned when necessary to execute missions, as ordered by the 

President or Secretary of Defense.121 NORTHCOM also plays an important role in disaster response by 

providing unique military capabilities to FEMA in support of state requests for emergency aid. NORTHCOM is 

the DOD synchronizer for all DOD support to FEMA and Defense Support of Civil Authorities (DSCA)—an 

agency that advances U.S. national security and foreign policy interests by building the capacity of foreign 

security forces to respond to shared challenges122—which gave NORTHCOM a much more proactive role 

during the 2018 hurricane season.123

During the 2017 hurricane season, NORTHCOM sent thousands of troops to hurricane-effected areas in 

Texas and Florida, and a DOD medical ship to Puerto Rico after Hurricane Maria struck in support of 

FEMA.

124 Through its experience, NORTHCOM has stated there a number of lessons learned from the 

 

113 Federal Research Division, Library of Congress, Military Support to Civil Authorities: The Role of the Department of Defense in Support of Homeland 

Defense, 2007; Title 10. U.S. Code – Armed Forces, as amended 2011, Vol. III §§ 3001 et seq. 114 Tim Naftali, “Send in the Cavalry: The President’s Powers in the Event of Disaster,” Slate, October 11, 2005. 115 EIS Council, “Protection Initiatives. Restoration and Response,” Webpage. 116 Claudette Roulo, “Defense Has Vital Role in Catastrophe Planning, Office Says,” American Forces Press Service, DOD, August 14, 2012. 117 DSCA, “Mission, Vision, and Values,” Webpage. 118 Statement by Robert G. Salesses and Brigadier General Joseph E. Whitlock, Defense of Civil Authorities: A Vital Resource in the Nation’s Homeland 

Security Missions, Hearing before the Subcommittee on Emergency Preparedness, Response, and Communications of the Committee on Homeland 

Security, House of Representatives, June 10, 2015. 

119 USNORTHCOM, “About USNORTHCOM,” Webpage. 120 Ibid. 121 USNORTHCOM, “U.S. Northern Command,” Webpage, May 16, 2013. 122 DSCA, “Mission, Vision, and Values,” Webpage. 123 USNORTHCOM, “U.S. Northern Command Prepares for Hurricane Florence,” Press release, September 13, 2018. 124 Scott Maucione, “NORTHCOM looking inward after huge hurricane season,” Federal News Network, February 15, 2018. 
47 

unprecedented season, including the need for better communication with affected communities and clearly 

defining the response necessary to provide better assistance.125 NORTHCOM says that an after-action report 

is currently being drafted that will be translated into how NORTHCOM responds to future hurricane seasons 

and disaster response. 

U.S. Indo-Pacific Command 

The U.S. Indo-Pacific Command (INDOPACOM) is a unified combatant command of the U.S. Armed 

Forces responsible for the Indo-Asia-Pacific region. Established in 1947, it is the oldest and largest of the 

unified combatant commands.126 Its commander, the senior U.S. military officer in the Pacific, is responsible 

for military operations in an area which encompasses more than 100 million square miles over roughly 52 

percent of the Earth’s surface, stretching from the waters off the west coast of the U.S. to the western 

border of India, and from Antarctica to the North Pole. The 36 nations comprising the Asia-Pacific region are 

home to more half of the world's population, 3,000 different languages, several of the world's largest 

militaries, and five nations allied with the U.S. through mutual defense treaties.127

Unlike NORTHCOM, INDOPACOM only has four U.S. jurisdictions within its area: Hawaii, Guam, American 

Samoa, and the Commonwealth of the Northern Mariana Islands (CNMI). When it comes to disaster 

response, any needed INDOPACOM forces are assigned from lead federal agencies such as FEMA to provide 

capabilities that do not exist in the civilian sector. Because four U.S. jurisdictions within its area are islands 

located up to 6,000 miles away from the U.S. mainland, this creates the potential for additional challenges 

that are not experienced elsewhere.

In 2018, a memorandum of understanding (MOU) was signed between DOE, DHS, INDOPACOM, and the 

state of Hawaii “to identify a framework for cooperation and partnership to strengthen coordination of 

effort to enhance national and state security.”128 The MOU’s goal is to create a cohesive and collaborative 

lens to look at the critical energy infrastructure interdependencies between the entities and the civil Energy 

Sector and identify vulnerabilities ahead of events and collectively develop mitigation approaches 

addressing those vulnerabilities. 

DOD and INDOPACOM are also supporting a new DHS- and Hawaii-led Defensive Cyber Industry Consortium 

(DCIC); an initiative to bring in stakeholders from lifeline sectors across Hawaii to emphasize 

interconnectedness of critical vulnerabilities and the need for collaboration and sharing information. Still in 

its nascent stages, DCIC was expected to launch in November 2018. 

INDOPACOM, in partnership with Resurgo, LLC (a Honolulu-based DOD contractor), the Hawaiian Electric 

Companies, and the Naval Facilities Engineering Command (NAVFAC), has also launched a Critical Energy 

Infrastructure Defense-In-Depth demonstration.129 It is aimed at exhibiting to the DOD and commercial 

energy providers a capability to mitigate and recover quickly from online and insider cyber activities 

directed against Supervisory Control and Data Acquisition (SCADA) infrastructure. The intrusion-tolerant 

focus of the demonstration will show how new technologies employed in a defense-in-depth configuration 

enable a utility grid SCADA system to fight though an attack without disruption of services.130

 

125 Jim Garamone, “Military Seeks to Learn Lessons of 2017 Hurricane Season,” DOD, December 11, 2017. 126 USINDOPACOM, “History of United States Indo-Pacific Command,” Webpage. 127 USINDOPACOM, “About USINDOPACOM: Headquarter, Unites States Indo-Pacific Command,” Webpage. 128 Memorandum of Understanding between the Department of Energy, the Department of Homeland Security, the U.S. Pacific Command, and the 

State of Hawaii for Critical Energy Infrastructure Interdependencies, February 8, 2018. 129 Ibid. 130 Kevin Jordan, “Critical Energy Infrastructure Cyber Defense-in-Depth,” SERDP, ESTCP, October 25, 2018. 
48 

Defense Threat Reduction Agency 

The Defense Threat Reduction Agency (DTRA) is an agency in DOD that is responsible for enabling DOD and 

the federal government to prepare for, prevent, and respond to risks and weapons of mass destruction

(WMDs) and improvised threats and to ensure nuclear deterrence.131 Established in 1998, DTRA supports 

efforts to prevent the proliferation and use of WMDs, perform research, and develop tools and capabilities 

in WMD and improvised threat environments.132

III. State and Local Government and Industry Roles 

Responsibility for responding to disasters begins at the local level. It is only after SLTT government resources 

have been overwhelmed, and the governor or chief tribal executive of the affected state or tribal nation has 

requested federal assistance that the federal government provides supplemental assistance.

133 However,

post-disaster recovery is so complex and wide-ranging that solutions do not fit neatly into individual

programs.134

The current approach to response, including the existing frameworks, is complex and difficult for local 

communities to navigate. The complexity of federal programs can hinder the speed and nimbleness of local 

and state response as leaders to spend time trying to figure out which program fits their recovery needs and 

tailoring their response to federal program rules.135

Existing frameworks do not identify who has ultimate decision-making authority or clearly define the roles

for state and local governments and the private sector during a catastrophic power outage. Disaster

declarations and resource allocations are made at the federal and state level, not the local level, which can

lead to a disconnect with the specific area affected. Even under the NPS,

136 there is a lack of clarity on the 

roles and responsibilities in responding to events.137

This section will provide an overview of the existing roles outside the federal government for state and local 

governments and industry during an event. 

Mutual Aid

Mutual aid agreements or mutual aid programs are arrangements among agencies, organizations, and 

jurisdictions that provide a mechanism to quickly obtain emergency assistance in the form of personnel, 

equipment, materials, and other associated services when a disaster or emergency event has depleted the 

resources of the affected area.138 Mutual aid programs produce rapid, short-term distribution of emergency 

support prior to, during, and after an event.139

There are different types of mutual aid agreements, ranging from formal ones adopted into statutes 

between states or countries to informal understandings among consortiums outlining how government and 

 

131 DTRA, Strategic Plan FY 2018-2022, March 2018. 132 Statement of Shari Durand, Countering Weapons of Mass Destruction Posture, Hearing before the Emerging Threats and Capabilities 

Subcommittee Committee on Armed Services, House of Representatives, March 23, 2017.

133 Jared T. Brown, et al., Congressional Primer on Responding to Major Disasters and Emergencies, Congressional Research Service, 2017. 134 Amy Liu, “Federal Post-Disaster Recovery: A Review of Federal Programs,” What Works Collaborative, May 2010. 135 Amy Liu, “Feds, States, Cities – The All of the Above Disaster Response,” Brookings, November 2, 2012. 136 DHS, National Preparedness System, November 2011. 137 DHS, Section 2(e): Assessment of Electricity Disruption Incident Response Capabilities, August 9, 2018. 138 FEMA, “Mutual Aid Agreements and Assistance Agreements,” 2018. 139 Ibid. 
49 

private resources will provide aid within a specific community.140 Participation in mutual aid is also a 

component of the NIMS.141

Emergency Management Assistance Compact

The Emergency Management Assistance Compact (EMAC) is a non-federal national interstate mutual aid 

agreement, administered by National Emergency Management Association (NEMA), which facilitates the 

sharing of resources across state lines in times of disaster or emergency.142 Beginning as a mutual assistance 

compact established by the Southern Governors Association (SGA) in response to Hurricanes Andrew and 

Hugo,143 it later became law when ratified by Congress in 1995. The compact was renamed EMAC and has 

been adopted by all 50 states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands.144

EMAC has become the United States’ state-to-state, predominantly used mutual aid system.145 EMAC can be 

used instead of, or in conjunction with, the federal disaster response system, to provide timely and 

cost-effective relief to states requesting help from other member states who understand the needs of areas 

that are struggling to preserve life, the economy, and the environment.146

Sector Mutual Aid Agreements

Sector mutual aid agreements and programs were highlighted as effective emergency response tools to 

provide assistance in the form of personnel, equipment, or other materials following a disaster to improve 

response. 

Mutual aid does have its challenges, including the complex logistics of arranging basic necessities of food, 

water, and shelter for workers during a disaster when there may be limited access and strained 

infrastructure. And while it is ultimately deemed to be cost-effective, there is a reimbursement 

requirement. In some instances, challenges may arise if an impacted area is difficult to get to, or potential 

crews that would respond have other obligations first due to pre-existing contracts or company structure. 

Energy Sector

For decades, electric utilities and public power authorities have provided assistance to each other following 

a disaster. There are two major mutual assistance programs led by the Edison Electric Institute (EEI) and the 

American Public Power Association (APPA), which work in coordination with the National Rural Electric 

Cooperative Association (NRECA).147 EEI’s mutual aid program enables utilities to increase the size of the 

workforce following an incident by “borrowing” resources from other member utilities.148 APPA’s mutual aid 

assures that personnel and resources from other utilities can support national outage events and receive 

federal reimbursement for expenses incurred during said events.149

Within the Energy Sector, the Electricity Subsector Coordinating Council (ESCC)—building on the industries’ 

culture of mutual assistance—has also formed the Cyber Mutual Assistance (CMA) Program.150 The program 

 

140 FEMA, “Mutual Aid Agreements and Assistance Agreements,” Webpage. 141 FEMA, “NIMS Frequently Asked Questions,” Webpage. 142 Trina Sheets, EMAC: A History and Analysis of the Evolution of National Mutual Aid Policy and Operations, The Council of State Governments, 

September 13, 2014. 143 Ibid. 144 Ibid. 145 Ibid. 146 FEMA, “EMAC Overview for NRF,” Webpage. 147 EEI, “Understanding the Electric Power Industry’s Response and Restoration Process,” October 2016; APPA, “Public Power Mutual Aid Playbook,” 

September 2014. 

148 EEI, “Understanding the Electric Power Industry’s Response and Restoration Process,” October 2016. 149 APPA, “Public Power Mutual Aid Playbook,” September 2014. 150 ESCC, “The ESCC’s Cyber Mutual Assistance Program,” January 2018. 
50 

is composed of industry cyber experts who can provide voluntary assistance to other participating entities in 

advance of, or in the event of, a disruption of electric or natural gas service, systems, and/or IT 

infrastructure due to a cyber emergency.151

Communications Sector

The Communications Sector has pre-established internal and external priorities for end-user restoration 

before, during, and after an event that are modified in conjunction with Emergency Support Function (ESF) 

#2 and National Coordinating Center protocols, as needed. In 2016, the Federal Communications 

Commission (FCC) adopted an order supporting a voluntary industry commitment to promote resilient 

wireless communications and situational awareness during disasters. The voluntary commitment was 

through the wireless providers AT&T, Sprint, T-Mobile, U.S. Cellular, and Verizon, together with CTIA, which 

formed a Wireless Network Resiliency Cooperative Framework which sought to enhance coordination and 

communication to better ensure wireless continuity during emergency events.152

Water and Wastewater Systems Sector

In the Water Sector, the Water and Wastewater Agency Response Network (WARN) serves as a network of 

utilities prepared to provide assistance through personnel, equipment, materials and other services to help 

respond and recover from an event.153

 

151 ESCC, “Frequently Asked Questions About Cyber Mutual Assistance,” January 2018. 152 Marsh et al., Final Network Resiliency Commitment Letter, 2016. 153 EPA, Mutual Aid/Assistance Agreements, 2011.
51 

Electric Infrastructure Security Council 

Since 2010, the Electric Infrastructure Security (EIS) Council has brought together senior government, utility, and 

NGO officials from North America, Europe, Israel, and across the world to review the threat of severe disruption of 

vital national infrastructures. EIS Council projects help utilities and their partners develop and implement cost 

effective, consensus-based protection measures by hosting frameworks for sustained coordination, planning, and 

best practice development. The Council’s Electric Infrastructure Security Summit (EISS) Series has become the 

primary international framework bringing together senior government, utility, and NGO officials from around the 

world to review the threat of disruption of vital national infrastructure. 

In 2017, the EIS Council launched EARTH EX, the first iteration of an annual, international, multi- and cross- sector 

exercise designed to build off of, and work with, existing large-scale exercises to address complex catastrophes 

spanning 14 countries, all FEMA regions, 44 states, 500 agencies and corporations, and 16 infrastructure sectors. 

The lessons learned from the exercise (e.g., there exists a global drive and motivation to work together to tackle 

resiliency) are being incorporated into upcoming Black Sky Playbooks and update curricula and exercises EIS 

makes available for government agencies and organizations who want to address black sky event planning.

EARTH EX 2018 occurred on August 22, 2018. 

The EIS Council has developed a series of handbooks for electric utilities, government, and stakeholders to reduce 

the scope and duration of a black sky event. The playbooks determine internal and external requirements for black 

sky survival, along with accompanying exercises and training. The EIS Council has also prepared a number of 

recommendations for improving resilience to black sky events, including recommending the development of 

performance-based metrics for improving resilience to black sky events. The metrics have the potential to be used 

in parallel with the EIS sector-by-sector Black Sky Playbooks to determine internal and external requirements for 

black sky survival and develop compliance lists that each sector would abide by with the potential for incentives 

and reimbursements. 

The Council is in the early stages of creating a working prioritization model with national and international 

partners of interconnected and interdependent systems that could cause cascading effects across sectors beyond 

human capabilities. EIS has also initiated a simulation effort for a global infrastructure network optimization 

model (GINOM) to possibly work with relevant interested parties in the private sector and government agencies 

such as DOE to explore the potential for joint development of a mapping effort for explicit interdependencies. 

Source: E-PRO Handbook, 2014; EIS Council
52 

Appendix E: Sector Interdependencies 

The interconnected nature of the critical infrastructure sectors creates mutual interdependencies that could 

exacerbate the consequences of a catastrophic power outage. There is a lack of understanding of the 

cascading, cross-sector interdependencies between infrastructure and what that means for prioritizing 

backup generation and other limited resources to maintain services and functions during a long-term, 

widespread outage. Understanding the complex interdependencies between electricity and other critical 

infrastructure sectors is key to effectively assessing the impact of a long-duration power outage.

This appendix provides an overview of the interdependencies between the Electricity Subsector and the Oil 

and Natural Gas Subsector, and the Communications, Financial Services, Water and Wastewater Systems, 

and Transportation Systems Sectors that could hinder or prevent power restoration during a catastrophic 

power outage.

There are a number of ongoing initiatives focused on building cross-sector coordination. For example, 

exercises in individual sectors are beginning to include additional sectors, and at the state and regional level 

efforts are being made to better understand the risks posed by these interdependencies. This appendix also 

highlights a few of these exercises that have addressed cross-sector issues.

I. Electricity Mutual Interdependencies 

Electricity is central to the functioning of all other sectors, and a catastrophic power outage would cause 

cascading failures across all of them. 

A. Natural Gas 

The Electricity Subsector is becoming more reliant upon natural gas as a fuel source; from 2002 to 2016, the 

share of electricity generated by gas-fired units increased from 18 percent to about 34 percent while the 

share generated by coal fell from about 50 percent to about 30 percent.154 The Energy Information 

Administration (EIA) has estimated that natural gas production will account for almost 40 percent of the U.S. 

energy production by 2040.155 The Department of Energy (DOE) found that “the electric sector’s growing 

reliance on natural gas raises concerns regarding the ability to maintain bulk power system (BPS) reliability

when facing constraints on the natural gas delivery systems.”156

Similar to other entities, the natural gas industry relies on electricity to operate industrial control and 

business systems. This section provides an overview of the structure and market of natural gas systems, 

potential risks, and some ongoing initiatives to build resilience. 

Natural Gas Structure and Markets

The construction of natural gas pipelines is driven by the market and demand. Pipelines are built to meet 

firm capacity, when there is a willingness and ability of customers (i.e., shippers) to financially commit to the 

gas that would be provided. Limited pipeline capacity in a particular region can be attributed to factors such 

as environmental regulations hindering construction and/or residents who do not want pipelines in their 

 

154 DOE, Staff Report to the Secretary on Electricity Markets and Reliability, August 2017. 155 EIA, Annual Energy Outlook 2017 with Projections to 2050, January 5, 2017. 156 NERC, Short-Term Special Assessment: Operational Risk Assessment with High Penetration of Natural Gas-Fired Generation, May 2016.
53 

communities. Also, there may be a general lack of incentive(s) among the generator community to contract 

for firm service. 

The pipeline system is designed to be redundant, with segmented pipes and looped/parallel pipelines, 

allowing natural gas to continue to flow despite potential disruptions in one section of a pipeline.157

According to a report by members of the Oil and Natural Gas Subsector, the natural gas system is highly 

resilient because the production, gathering, processing, transmission, distribution and storage of natural gas 

is geographically diverse, highly flexible and elastic, and characterized by multiple fail-safes, redundancies 

and backups.158

Natural gas is compressible, which allows natural gas to be stored near markets underground in geological 

formations and as liquefied natural gas (LNG) at aboveground facilities. Most compressor stations are run 

using natural gas and would not be affected by a loss of commercial electricity. If a compressor were to 

cease operating, natural gas could continue to flow, though at a somewhat lower capacity. Some natural gas 

pipeline companies have identified critical locations, including those with electric compressors, and have 

worked with their electricity service providers to ensure they have prioritized power when electricity is 

restored following an outage. 

If pipelines and the compressor stations that maintain pressure within them are compromised, gas could 

continue to flow to generators at steadily diminishing levels rather than being abruptly halted.159 The 

combination of sustained post-event gas flows and rapid restoration could enable generators to face only 

brief, low-impact interruptions.160 However, interruptions could last longer if restoration is slow. 

Compressors and industrial control systems that keep gas flowing to power generators and other users are 

more and more reliant on electric power. While some compressor stations do have emergency power 

generators and at least some on-site fuel to sustain operations, a break in the flow of electricity could 

disrupt the flow of gas when backup power runs out, which could cause further fuel interruptions.

161 This

growing interdependency create risks of cascading, mutually-reinforcing failures across both the Electricity 

Subsector and Oil and Natural Gas Subsector.

162

Potential Risks

Reliance on a single fuel creates the danger of “common mode failures” where a lack of natural gas 

incapacitates multiple generators simultaneously, which could create power outages lasting a month or 

longer over multiple regions of the U.S.

163 During a catastrophic outage, on-site fuel supplies for emergency 

generators will quickly be depleted. Massive, multi-sector requirements for fuel resupply would occur, and 

contractors responsible for resupply operations will likely be unable to meet these requirements. For 

example, New England is especially susceptible to these concerns because it has limited “fail-safe” 

 

157 NERC, 2017 Long-Term Reliability Assessment, 2017. 158 ONG SCC and NGC, Defense-In-Depth: Cybersecurity in the Natural Gas & Oil Industry, September 2018. 159 Statement of Paul Stockton, Fuel Resilience for the Bulk Power System: Threat-Based Modeling and Analysis. Response to the Grid Resilience 

Order, Grid Resilience in Regional Transmission Organizations and Independent System Operators, 162 FERC, 61,012, May 8, 2018. 160 Ibid. 161 Ibid. 162 Paul Stockton, E-PRO Handbook II: Volume 1 Resilient Fuel Resources for Power Generation in Black Sky Events, EIS Council, 2016. 163 Statement of Thomas S. Popik, Reply Comments of the Foundation for Resilient Societies, FERC, Reliability Technical Conference, November 7, 

2017. 
54 

infrastructure with limited trucking capability to serve the entire region and it has a high reliance on natural 

gas supply and LNG imports to meet winter peak loads.164

Given the limited number of pipelines and supporting gas infrastructure in New England, the loss of even a 

single natural gas compressor station or other gas system facility would create recurring energy shortages 

that would cause frequent and long rolling blackouts.165 ISO-NE recently implemented two new initiatives to 

address the risk of winter energy shortages by beginning to publish a 21-day look-ahead energy forecast 

that describes expected conditions, from normal to conditions requiring declaration of an energy alert or an 

energy emergency, and a change to ISO-NE energy market. The second initiative, in the daily energy market, 

will provide each generator with an estimated opportunity cost that can be incorporated into its offer price 

for the next day. Each morning, the next day’s opportunity costs will be calculated for each generator and 

provided to resource owners.166

Natural gas disruptions could also cause ripple effects across supply chains, whose corruption could pose 

significant challenges.167 In the event of significant damage to physical pipeline infrastructure, service 

restoration for natural gas is time-consuming and expensive. Federal authorities do not have an estimate on 

the amount of time it would take to recover if natural gas was shut off in a vast portion of the U.S. such as 

the East Coast.

168 A 2018 report prepared for Southern California Gas examined the resilience of natural gas 

infrastructure in disasters and recommended utilities sub-divide their gas systems so that when service 

isolation is necessary it can be done on a more granular level.169

 

Blackstart Capabilities

Blackstart generation is used to restart the electric system in a blackout. Blackstart generators can start without 

electricity from the grid and assist in system restoration. This is especially important in the face of a long-term 

outage. The reliance on a single fuel blackstart without fuel storage capacity or firm fuel arrangements may cause 

issues during a restoration event. Single fuel blackstart generator owners should develop alternative fuel 

capability or coordinate with their fuel providers to mitigate this risk. Regional Transmission Organizations (RTOs) 

and Independent System Operators (ISOs) have existing blackstart plans that are routinely exercised and built 

upon, but there is a desire for the government to be more involved. 

RTOs and ISOs build relationships with natural gas suppliers to bolster situational awareness. While RTOs and ISOs 

are not able to instruct them how to divert resources, they can work with market participants to identify where 

fuel supplies are running low and assist in that coordination. For example, the energy company ConEdison has 

proposed a number of programs and projects to address the growing demand for natural gas in its service area. 

This includes building several new compressed natural gas storage sites to reduce the need for conventional 

pipeline supplies. 

Source: NERC, GridEx IV: Lessons Learned; EPRO Handbook II, Vol. I; Utility Drive, Oct. 5

164 NERC, 2017 Long-Term Reliability Assessment, 2017. 165 ISO New England, Operational Fuel-Security Analysis, January 17, 2018. 166 ISO Newswire, “ISO-NE is implementing near-term changes in both operations and markets to help address the risk of winter energy shortage,” 

Press release, November 2, 2018. 

167 NERC, CIP-013-1 – Cyber Security Supply Chain Risk Management Plans, April 2017. 168 Blake Sobczak, et al., “Cyber raises threat against America's energy backbone,” E&E News, May 23, 2017. 169 ICF, Case Studies of Natural Gas Sector Resilience Following Four Climate-Related Disasters in 2017, Southern California Gas Co, 2018. 
55 

Existing and Proposed Standards and Guidelines 

There are existing guidelines and plans that direct the 

safety and security of the natural gas pipeline 

system.170 For example, the Pipeline Security and 

Incident Recovery Protocol Plan (the Plan), was 

completed in 2010 as required by the 9/11 

Commission Act of 2007171 by the Transportation 

Security Administration (TSA) and the Pipeline and 

Hazardous Materials Safety Administration (PHMSA). 

The Plan acted as a framework to support the recovery 

of pipeline infrastructure and establish measures to 

prevent a security incident and enhance pipeline 

resiliency.172 Within the federal government, the Plan 

mainly applies to TSA and PHMSA, identifying ways 

they can provide increased security support to the 

critical interstate and intrastate natural gas and 

hazardous liquid transmission pipeline infrastructure 

when threatened and how the government will work 

to ensure continued transportation of product 

following an incident.

The North American Electric Reliability Corporation 

(NERC) has offered a set of recommendations on 

opportunities for gas-electric coordination, many of which might be supported by data to facilitate broader 

assessments of fuel resilience and collaborative mitigation measures.173 And while there are NERC 

standards, NERC reliability standards apply to electric infrastructure, not gas transmission lines and other 

fuel systems on which the grid depends. Natural gas does not have mandatory reliability standards directly 

comparable to the bulk electric system. “We need an in-depth understanding of the resilience of our 

electricity and the related, supporting infrastructure in order to know how best to either modify existing 

market structures or build new resiliency standards into the system.”174

The Oil and Natural Gas Subsector Coordinating Council (ONG SCC) is working closely with other sectors 

through Information Sharing and Analysis Centers (ISACs), through DOE and Department of Homeland 

Security (DHS) tabletop exercises (e.g., GridEx, National Level Exercise (NLE), ClearPath), through state-led 

exercises, and through direct coordination with the Electricity Subsector Coordinating Council (ESCC). 

 

Natural Gas and Cybersecurity

The American Petroleum Institute (API), the Natural 

Gas Council (NGC), and the wider membership of

the ONG Subsector Coordinating Council (SCC)

released a report in October 2018 describing steps 

the industry has taken to improve its resilience to 

cyber threats. The report emphasized the industry’s 

preference for voluntary mechanisms including 

frameworks and public-private collaboration, rather 

than rigid standards or regulations, to provide the 

necessary flexibility and agility to respond to a 

constantly-changing cyber threat landscape. 

The National Risk Management Center (NRMC) is 

also working with TSA, DOE, the Federal Energy 

Regulatory Commission (FERC), and the Electric 

Subsector Coordinating Council and Oil and Natural 

Gas Subsector Coordinating Council on cyber and 

physical risks to natural gas pipeline infrastructure. 

Source: ONG SCC and NGC, Defense-in-Depth: 

Cybersecurity in the National Gas and Oil Industry 

report

B. Communications Sector 

Restoration and recovery are next to impossible without working communications. Existing plans and 

exercises across all sectors rely on the ability to coordinate response through voice or data communications. 

Current emergency communications systems are unlikely to provide the multi-sector connectivity and 

170 DHS, Pipeline Security Guidelines, March 2018; Peter Behr and Blake Sobczak, “TSA to expand gas pipeline cybersecurity oversight,” E&E News, 

December 22, 2017. 

171 9/11 Commission Act of 2007, Pub. L. 110-53. 172 A security incident is any event determined by DHS/TSA to be significant enough to begin monitoring the situation for further developments. 173 Statement of Paul Stockton, Fuel Resilience for the Bulk Power System: Threat-Based Modeling and Analysis. Response to the Grid Resilience 

Order, Grid Resilience in Regional Transmission Organizations and Independent System Operators, 162 FERC, 61,012, May 8, 2018. 174 Bruce Walker, Testimony Before the United States Senate Committee on Energy and Natural Resources, January 23, 2018. 
56 

interoperability that will be essential in catastrophic power outages.

175 Voice and data communications are 

used for normal business functions (e.g., personnel records, payroll systems) and for supervisory control and 

data acquisition (SCADA), crew dispatch, and control of electricity generation and delivery. 

Communication networks were designed for power outages that are infrequent or of short duration; backup 

generators and fuel storage are designed to support an outage of a few hours to a few days. 

Communications systems will require fuel for generators, but pipeline pumping stations, storage depots, 

and truck distribution could be affected by a catastrophic power outage, preventing the necessary resupply 

needed for communications networks to continue to operate. Current battery technology, due to its limited 

lifespan, would most likely not have a significant impact in reducing dependencies and/or 

interdependencies during a long-term outage.176

Without communications, crucial sector operations would grow increasingly difficult over extended periods 

of time since manual operations, when they are possible, depend on timely communications. Most 

companies have satellite-based phones and radio communications, but these systems need to be properly 

maintained and tested. 

The President’s National Security Telecommunications Advisory Committee (NSTAC), a presidential advisory 

council focused on reliable telecommunications, released two reports in 2006 on the interdependency 

between the Communications Sector and Electricity Subsector and how this could be impacted by a longterm outage in one or both sectors. While the reports were completed more than a decade ago, a number 

of the conclusions and recommendations are still relevant. For example, the need to identify and prioritize 

adequate fuel resupply to maintain backup power for communication systems, and the lack of clarity on the

transition from local to national management of a long-term outage.177

There are a number of ongoing efforts to address emergency communications platforms and processes, and 

prior efforts may provide lessons learned. 

Prior Efforts 

• The Critical Infrastructure Warning Information Network (CWIN) was a DHS program designed to 

create a hardened communications system as a stand-alone, independent network that connected 

the government and critical sector owners and operators to coordinate recovery and reconstruction 

following an event. CWIN was established in 2001 and funded through 2010, with a budget of $30 

million in 2003 alone. During its existence, CWIN included 51 state Emergency Operation Center 

(EOCs), 163 federal and state representatives, and had 160 client terminal sites across the United 

States, and all states and the main ISACs were connected.178 Though it is unclear why CWIN was 

discontinued, because by all assessments it was well managed and operating effectively, CWIN may

have come before its time. There was no protocol on information sharing liability in the early 2000s, 

which could have made it difficult to demonstrate that the value of the program justified the 

expense. 

 

175 EIS Council, “Black Sky Emergency Communication & Coordination System: BSX,” Webpage. 176 CSCC and Communications-ISAC, “Communications Sector Response to DHS Data Call – Executive Order 13800,” July 28, 2017. 177 NSTAC, NSTAC Report to the President on Telecommunications and Electric Power Interdependencies: The Implications of Long-Term Outages, 

December 2006.

178 DHS, “IT Program Assessment: NPPD – Critical Infrastructure Warning Information Network (CWIN),” Report; DHS, “Privacy Impact Assessment for 

the Critical Infrastructure Warning Information Network,” January 7, 2006. 
57 

Ongoing Initiatives 

• The ESCC Resilient Communications Working Group has identified the need to update, modernize, 

and move some of the underlying systems out of private networks, partially because real-time 

coordination across multiple sectors makes voice and data telecommunications critical for operation 

of the grid.179 This Working Group has created a policy principle statement supporting emergency 

communications to validate and formalize the current work being done with the Communications 

Sector. The ESCC has also recommended that some form of backup communications capability to 

restore the grid after a major disaster needs to be created. 

• The Black Sky Emergency Communications and Coordination System (BSX)—an interoperable, 

secure system that can incorporate a range of communication technologies to support grid re-start 

activities—is being developed by the Electric Infrastructure Security (EIS) Council as a means to 

provide secure communications during an event.180 A BSX system will have the ability to:181

o Survive electromagnetic pulse (EMP) attacks, cyberattacks, catastrophic earthquakes, and 

other black sky hazards. 

o Continue functioning in the absence of grid-provided power for a month or more. 

o Withstand adversarial efforts to disrupt communications or corrupt the integrity of data 

flows. 

o Provide critical voice and data connectivity for situational awareness, sustainment, and 

restoration operations across multiple regions of the United States. 

o Provide an engine for decision support, keyed to the unique requirements of the local users’ 

equipment, sector by sector, adequate to help manage the scale of a black sky complex 

catastrophe. 

 There could be reinvestments to FNARS (Federal Emergency Management Agency’s

(FEMA’s) National Radio System)—the Agency’s high frequency (HF) radio network 

that provides a minimum essential emergency communications capability among 

federal, state, local commonwealth, and territorial governments in times of 

national, natural and civil emergencies.

182

C. Water and Wastewater Systems Sector

Water and energy are resources that are reciprocally and mutually linked, because energy needs require 

water—through mining, fuel production, hydropower, and power plant cooling—and water needs energy—

to pump it, treat it, distribute it, and discharge wastewater.183 There are almost 200,000 drinking water 

treatment systems in the U.S., and roughly 15,000 water treatment facilities.184 About 85 percent of the U.S. 

is supplied by 5 percent of the drinking water system.185

The Energy Sector’s water consumption is projected to rise 50 percent from 2005 to 2030.186 According to a 

2010 Congressional Research Service report, “The more water used by the energy sector, the more 

 

179 NSTAC, NSTAC Report to the President on Telecommunications and Electric Power Interdependencies: The Implications of Long-Term Outages, 

December 2006.

180 EIS Council, “Black Sky Emergency Communication & Coordination System: BSX,” Webpage. 181 Paul Stockton, E-PRO Handbook III Cross-Sector Coordination and Communications in Black Sky Events, EIS Council, 2018. 182 FEMA, “Non-Federal Outreach and Technical Assistance Offerings,” Report, 2018. 183 Claudia Copeland and Nicole T. Carter, Energy-Water Nexus: The Water Sector’s Energy Use, Congressional Research Service, January 24, 2017. 184 NIAC, Water Sector Resilience: Final Report and Recommendations, June 2016. 185 Ibid. 186 Nicole T. Carter, Energy’s Water Demand: Trends, Vulnerabilities, and Management, Congressional Research Service, November 24, 2010. 
58 

vulnerable energy production and reliability is to competition with other water uses and water 

constraints.”187

Without water services, factories shut down, hospitals close, communities are disrupted, and most hotels, 

restaurants, and businesses cease operations.188 If water and wastewater systems failed in communities 

across multiple states or U.S. regions, the societal consequences and risk to the lives and safety of affected 

populations would be difficult to overestimate.189 As the U.S. Environmental Protection Agency (EPA) put it, 

“water infrastructure damage can adversely affect the operation of all other critical infrastructure sectors. 

Conversely, damage to other critical infrastructure sectors could negatively affect drinking water and 

wastewater services, thereby creating an infrastructure interdependency.”190

A growing number of electric utilities are installing their own emergency power generators or arranging with 

partners (including the U.S Army Corps of Engineers (USACE)) to install generators when an emergency 

strikes. Many utilities are also expanding their capacity to store generator fuel onsite, and are improving 

their ability to provide mutual assistance when severe events occur.191

The EIS Council has been working with American Water, Aqua America, and the American Water Works, 

developing black sky playbooks and a Water Sector Electric Infrastructure Protection (E-PRO) Handbook for 

individual water and wastewater systems. A 2016 E-PRO Handbook recommended establishing minimal 

sustainable service levels with infrastructure investments and developing plans to achieve those service 

levels to strengthen the resilience and ability of water and wastewater systems to sustain emergency 

operations.

192

A 2018 American Water Works Association after-action report on Hurricanes Harvey and Irma

recommended that DHS and FEMA establish a policy that designates water and wastewater services as top 

priorities for power restoration.

193 The report emphasized that given the critical lifeline functions the Water 

and Wastewater Systems Sector provide communities for response and recovery such as fire protection and 

public health and safety, water systems should have top priority status when power supply is at risk.194

Sustaining drinking water and wastewater services reduces pressure on other emergency management 

needs, supports shelter in place capabilities, and allows for continued economic activity.195

D. Transportation Systems Sector

In 2017, 29 percent of U.S. energy consumption was for transporting people and goods.196 As the NIAC 

noted in its 2015 Transportation Sector Resilience: Final Report and Recommendations, “America’s 

transportation system is a very complex ‘system of systems,’ with seven distinct modes; a diverse ownership 

across the private sector and federal, state, local, and regional jurisdictions; and a vast array of services to 

move people and freight. This diversity complicates transportation planning, funding, design, and operations 

and presents significant challenges for integrating resilience into infrastructure and organizational 

 

187 Nicole T. Carter, Energy’s Water Demand: Trends, Vulnerabilities, and Management, Congressional Research Service, November 24, 2010. 188 NIAC, Water Sector Resilience Final Report and Recommendations, June 2016. 189 Paul Stockton, E-PRO Handbook II: Volume 2 Water: Water Sector Resilience for Black Sky Events, EIS Council, 2016. 190 EPA, “Understanding Water Sector Interdependencies,” Fact sheet. 191 Paul Stockton, E-PRO Handbook II: Volume 2 Water: Water Sector Resilience for Black Sky Events, EIS Council, 2016. 192 Ibid. 193 American Water Works Association and Water/WARN, Hurricanes Harvey and Irma After-Action Report, 2018. 194 Ibid. 195 Ibid. 196 EIA, Monthly Energy Review, Table 2.1, April 2018. 
59 

practices.”197 The seven distinct modes include: aviation, highway and motor carrier, maritime 

transportation system, mass transit and passenger rail, freight rail, postal and shipping, and pipeline 

systems.198 Across these modes, limited or degraded transportation systems in an affected area during a 

catastrophic power outage could hinder response and restoration by delaying supplies or preventing 

individuals from traveling to their homes or other safe areas. 

The Pacific Northwest Cascadia Rising Exercise determined that catastrophic plans were inadequate for a 

scenario of that magnitude because current response plans are developed assuming that fundamental 

capabilities, such as communications and transportation, would be functional.199 The exercise determined 

that failure to quickly prioritize critical transportation routes for evacuation and clearance delayed the 

restoration of key routes in and out of impacted areas and that an overreliance on single modes of

transportation, such as rotary-wing aircraft, quickly created a bottleneck. Most notably, the exercise 

illuminated that transportation agencies tend to function in silos, with minimal collaboration with other 

participating entities to pool information and assets, causing information gaps and a lack of awareness of 

resources available for assistance. 

This was notable after Hurricane Maria struck Puerto Rico. One of the biggest lessons learned and massive 

limiting factor for response on the island was the time and effort to get supplies and personnel to the island. 

In the continental United States, supplies can be sent through a variety of methods (e.g., truck, rail, plane), 

but there were only two ways to get supplies to Puerto Rico—airports and sea ports—both of which were 

damaged. Given the limited ways to transport supplies, they were only able to send a certain number of 

planes each day. The result was that supplies for power restoration were competing with public health and 

safety supplies and priorities. 

E. Financial Services Sector

The Financial Services Sector consists of investment institutions, insurance companies, credit and financing 

organizations, and the infrastructure that enables these businesses to function.200 Financial Services Sector 

disruptions can also have cascading impacts on other sectors that require financial data systems for 

day-to-day operations. 

The Electricity and Financial Services Sectors are not only interconnected, but also underpin all other 

sectors.201 The Homeland Security Advisory Council (HSAC) Cybersecurity Subcommittee stated in its 2016 

report that these sectors along with the Communications Sector face rapidly growing cyber threats, and 

because of other sectors’ reliance on them, could be attractive targets for a cyber attack.202 For example, in 

2012, several financial institutions large and small withstood coordinated distributed denial-of-service 

(DDoS) attacks.203

In 2016, the CEOs of eight banks—Bank of America, BNY Mellon, Citigroup, Goldman Sachs, JPMorgan 

Chase, Morgan Stanley, State Street, and Wells Fargo—came together to proactively identify ways to 

enhance the resilience of the critical infrastructure underpinning much of the U.S. financial system. They 

created a long-term strategic initiative that performs deep analyses of systemic risk across financial products 

 

197 NIAC, Transportation Sector Resilience: Final Report and Recommendations, July 10, 2015. 198 DHS, “Transportation Systems Sector: Sector Overview,” Webpage. 199 FEMA, Emergency Managers Announce Improvements After Cascadia Rising Exercise, June 7, 2017. 200 DHS, “Financial Services Sector,” Webpage. 201 NIAC, Securing Cyber Assets, August 2017. 202 HSAC, Final Report of the Cybersecurity Subcommittee: Part I-Incident Response, 2016. 203 DHS, “Financial Services Sector-Specific Plan 2015,” Report. 
60 

and practices, known as the Financial Systemic Analysis and Resilience Center (FSARC). The FSARC's mission 

is to proactively identify, analyze, assess and coordinate activities to mitigate systemic risk to the U.S. 

financial system from current and emerging cyber security threats through focused operations and 

enhanced collaboration between participating firms, industry partners, and the U.S. government.204

The FSARC leverages the expertise of participating banks’ information/cyber-security teams with that of its 

government partners, including the Department of Treasury, DHS, and the Federal Bureau of Investigation 

(FBI).205

II. Cross-Sector Exercises

There are a number of existing exercises that bring together key stakeholders across industry and 

government to test plans, identify gaps that need to be addressed, and develop relationships before disaster 

strikes. This section provides an overview of some recent exercises that could be enhanced or built upon to 

test preparedness and response to a catastrophic power outage. 

A. GridEx IV

NERC conducted its fourth biennial grid security and emergency response exercise, GridEx IV, from 

November 15–16, 2017.206 With 6,500 individuals and 450 organizations participating across industry, law 

enforcement, and government agencies, GridEx IV provided an opportunity for various stakeholders in the 

Electricity Subsector to respond to simulated cyber and physical attacks that affect the reliable operation of 

the grid, fulfilling NERC’s mission to assure the effective and efficient reduction of risks to the reliability and 

security of the BPS.207

Led by NERC’s E-ISAC, GridEx IV was the largest geographically distributed grid security exercise to date. In 

addition to the distributed play portion of GridEx IV, a six-hour executive tabletop exercise involved industry 

executives and senior government officials.208 The tabletop exercise was facilitated as a structured 

discussion for industry and government to share the actions they would take and issues they would face in 

responding to the scenario. Participants articulated the severe limitations and barriers that would need to 

be addressed, both independently and collaboratively, to respond.209

The exercise identified some action items that need to be addressed. The most relevant for this study

include:210

• The need for increased shared understanding of the risk environment in different communities from 

a long-duration power outage to ensure there are answers before an event occurs. 

o This would require a coordinated effort starting at the local level then going to the state and 

federal level, with clear roles and responsibilities across all parts of government to divide or 

align efforts.

• There has been no assessment of the mismatched supply of generators and fuel for backup 

generators across multiple infrastructure sectors. 

 

204 “Financial Systemic Analysis & Resilience Center Appoints Scott DePasquale As President,” PRNewswire, March 15, 2017. 205 FS-ISAC, “FS-ISAC Announces the Formation of the Financial Systemic Analysis & Resilience Center (FSARC),” News Release, October 24, 2016. 206 NERC, Grid Security Exercise GridEx IV: Lessons Learned, March 2018. 207 Ibid. 208 Ibid. 209 Ibid. 210 Ibid. 
61 

• The government needs to provide continual, proactive support through tighter coordination with 

industry. 

o The government needs to stop providing episodic support and simply reacting to events, 

and provide continuous support to industry through increased coordination.

• Expand GridEx IV further because the current exercise did not offer an effective opportunity for 

electric utilities to exercise their external communications response plans with external 

organizations, such as law enforcement and state emergency managers.

B. Dark Sky Exercise

In May 2018, the State of Wisconsin held Dark Sky, which simulated a long-term, mass power outage across 

a wide swath of Wisconsin (45 counties—approximately two-thirds of the state—affecting 2.8 million 

people) to test how Wisconsin Emergency Management (WEM), local emergency management officials, the 

Wisconsin National Guard, first responders, and private utilities would respond to an outage’s second and 

third order effects. 

The purpose of the exercise was to test existing emergency and contingency plans, and to increase the 

understanding of the coordination, policies, and procedures required to conduct a joint inter-agency 

response to cyber and physical threats and subsequent attacks on infrastructure. 

The exercise was conducted May 15-17, 2018 at 19 

different locations in Wisconsin and included more 

than 1,600 participants from more than 240 agencies 

and departments across all levels of government and 

the private sector. It also included a cyber range to 

simulate a cyber-physical attack on grid infrastructure, 

which brought together public and private sector 

participants as part of a Red Team/Blue Team scenario. 

The exercise was also an opportunity for the state to 

test its separate secure fiber line that connects the 

State Emergency Operation Center, Joint Operations 

Center and key private sector entities. 

Dark Sky was the culmination of a multi-year planning cycle, which built on the state’s participation in prior 

exercises including GridEx IV November 2017 and the 2017 and 2018 annual Statewide Mobile Interoperable 

Communications exercises. The state was also part of FEMA Region V Power Outage Incident Annex (POIA) 

planning and workshops. Wisconsin used the exercise to test a draft emergency fuel plan and state-level 

fuel stakeholder coordination procedure. The state intends to use lessons learned from Dark Sky to inform 

development of a statewide emergency fuel plan. 

C. Cascadia Rising

The Cascadia Rising 2016 Exercise was a two-year effort to test and validate plans for a 9.0 magnitude 

earthquake along the 700-mile Cascadia Subduction Zone (CSZ) fault with subsequent tsunamis and 

aftershocks, impacting California, Oregon, Washington, and potentially Idaho.211

 

In March 2015, the Wisconsin Department of 

Military Affairs (which includes the Wisconsin 

National Guard and WEM) and the seven private 

sector electric utilities in the state formally 

established a public-private partnership. In 2017, 

the parties established the Wisconsin Utilities 

Coordination Group to support joint planning and 

formalize a system to coordinate activities during 

an emergency. 

Source: Wisconsin Department of Military Affairs

211 FEMA, Emergency Managers Announce Improvements After Cascadia Rising Exercise, June 7, 2017. 
62 

The exercise spanned local, state, tribal, and federal governments, the military, private sector, and 

nongovernmental organizations (NGOs) in a simulated field response to the aftermath of a disastrous CSZ 

earthquake and tsunami. Specifically, the exercise aimed to test the ability of EOCs in the region to 

coordinate and communicate priorities and objectives, share situational information, and request, order, 

and transport life-saving resources to impacted areas in the event of such a scenario. 

The exercise highlighted that catastrophic plans should encompass the full planning process: from 

formation, understanding the scenario, determining goals and objectives, and decision making, to 

development, implementation, and maintenance. A clear and aligned prioritization system should be 

developed for local areas to work with state and federal entities. Other lessons learned that are most 

relevant to this study include:

• Jurisdictions should anticipate widespread communications outages and pre-identify alternate 

communication strategies before a catastrophic event occurs. 

o The pocket of communication infrastructure that will remain accessible and functional in a 

heavily degraded state will need to be able share vital information to the public with the 

correct messaging.

• All jurisdictions should consider extending access to their information management and 

collaboration systems to external partners as needed, while ensuring the appropriate moderation 

and maintenance required to sustain any increased access.

• Partnerships with private and military assets would greatly expand the transportation options 

available. Processes for formalizing new relationships need to be streamlined to an expedited 

process during disaster response.

D. Liberty Eclipse 

DOE’s Liberty Eclipse exercise in November 2018 was intended be a “hands-on” test of the grid’s ability to 

bounce back from a blackout, simulating the painstaking process of re-energizing the power grid while 

squaring off against a simultaneous cyberattack on electric, oil and natural gas infrastructure.212

The goal of the Liberty Eclipse exercise was to prepare the response to a major incident caused by cyber 

attacks that could be frequent events in the near future. The exercise emphasized the blackstart process 

that utilities that have to restore electricity following massive blackouts first need to receive an initial jump 

of electricity before they can start generating it.213 The 2018 Liberty Eclipse exercise focused on reenergizing the grid and was expected to further examine the Electricity Subsector’s reliance on natural 

gas.214 It featured a two-day tabletop exercise for grid and oil and natural gas representatives, ahead of an 

operational drill of the step-by-step process for restoring electricity following massive blackouts.215

An after-action report is planned that will contain lessons learned and strategies to protect the grid against 

emerging cyber threats.216 DOE aims to make the Liberty Eclipse exercise a recurring, regionally focused 

supplement to GridEx.

 

212 Blake Sobczak, “DOE to vet grid’s ability to reboot after a cyberattack,” E&E News, August 3, 2018. 213 Pierluigi Paganini, “Dept. of Energy announced the Liberty Eclipse exercise to test electrical grid against cyber attacks,” Security Affairs, August 6, 

2018. 

214 Blake Sobczak, “DOE to vet grid’s ability to reboot after a cyberattack,” E&E News, August 3, 2018. 215 Ibid. 216 Ibid. 
63 

Appendix F: Individual and Community Preparedness 

Efforts 

Ultimately all events, from small to large disasters, are local.217 This means that those closest to impacted 

areas are the true first responders during any emergency or disaster—from individuals to families to

neighbors and local communities.218 However, there remains an ongoing myth that the federal government 

will be able to provide assistance and resources directly after an event to help with response, and that is not

always the case. 

State and local governments have a better understanding of the needs of their communities and have 

established relationships with owners and operators that will need to be called on following an event. 

Therefore, a solid capacity at the local and state level to respond to the needs of people is of upmost 

importance. The more communities can do to focus on preparedness before an event occurs, the more 

likely they are to have better outcomes following an event. 

However, not all communities are at the same level of preparedness. This means that any planning needs to 

recognize that each community exists in its own context and there is not a one-size-fits-all approach for 

preparedness. 

As the frequency and severity of disasters increases, there are two key ways communities build up their 

capacity and capabilities:

1. Accountability at the individual level for people and the local community.

2. Investment in infrastructure and community development that can make a big difference in a 

community’s resilience. 

State and local efforts are necessary to build community and individual resilience. This includes increased 

outreach and education for businesses and the general public on steps they can take to survive in place, 

improved personal preparedness, and support and sustainment of the local workforce that will be critical to 

infrastructure restoration. 

There are a number of ongoing efforts aimed at building individual and community resilience, including 

state initiatives and the work being done by the National Institute of Standards and Technology (NIST) 

Community Resilience Program. This appendix provides a high-level overview of those efforts. 

 

National Voluntary Organizations Active in Disaster 

The National Voluntary Organizations Active in Disaster (NVOAD) is a nationwide coalition of organizations that 

work together to help communities prepare for and recover from disaster. It is made up of nongovernmental 

organizations (NGOs) and faith-based and community-based organizations and promotes cooperation, 

communication, coordination, and collaboration among members to create a more effective delivery of services to 

communities affected by disaster. 

NVOAD also provides specific liaisons to work at designated Department of Homeland Security (DHS)/Federal 

Emergency Management Agency (FEMA) locations to support Emergency Support Function (ESF) #6.

217 FEMA, DHS, “Unit Four: Emergency Management in the United States,” Webpage. 218 FEMA, 2018-2022 Strategic Plan, 2018. 
64 

I. Examples of State Government Initiatives for Community 

Preparedness 

Although federal and state entities provide preparedness resources to individuals through websites, 

campaigns, and pamphlets, examples observed in the state of Washington, Oregon, and Hawaii reveal 

additional possible efforts that could better ensure the safety of the public during a catastrophic power 

outage.

• Washington: After the 2016 Cascadia Rising 

exercise—which tested the Pacific Northwest's 

ability to not only survive but recover from a 

Cascadia Subduction Zone earthquake and 

resulting tsunami219—identified issues with 

transportation, evacuation, sheltering and 

significant time before regional response 

agencies and neighboring states send 

assistance,

220Washington and representatives 

from regions, cities, and counties of the entire 

state, voted to change the disaster 

preparedness timeline previously at 3 days to 

14 days or more. The state has provided 

information on creating a Disaster Go To Kits 

and ways to stockpile food within homes.221

• Oregon: Oregon’s Office of Emergency 

Management encourages people to be prepared to be on their own for a minimum of two weeks, 

and provides detailed guides in time increments, from 2 minutes, 2 hours, 2 days, and 2 weeks after 

an event.222 This lessens the strain on emergency responders who need to focus limited resources 

on injured and other vulnerable populations immediately following a disaster.223

• Hawaii: Hawaii’s Emergency Management Agency (HI-EMA) launched a 2 Weeks Ready Campaign to 

inform the public of the necessary plans, kits, and procedures for a disaster with widespread 

impacts beyond the standard 72 hours.224 There is also a Hawaii Hazards Awareness and Resilience 

Program (HHARP) to help communities prepare to be self-reliant during and after events.225

 

Community Emergency Response Team (CERT) 

Program 

FEMA’s CERT program is designed to help 

communities prepare for effective disaster response 

through training and preplanning. CERT educates 

volunteers about disaster preparedness for the 

hazards that may impact their area and trains them 

in basic disaster response skills, such as fire safety, 

light search and rescue, team organization, and 

disaster medical operations. There are more than

2,700 local CERT programs nationwide, with more 

than 600,000 individuals trained since CERT became 

a national program. 

Source: FEMA, Community Emergency Response 

Team, Webpage 

219 FEMA, Cascadia Rising 2016 Exercise: Joint Multi-State After Action Report, September 6, 2016; Emergency Management Division Washington, 

“Preparedness,” Webpage. 

220 Ocean Shores, “Disaster Preparedness – 3 Days, (72 Hours) is NOT Sufficient,” Webpage. 221 Snohomish County, “Snohomish County Disaster Preparedness Guide,” Webpage, January 2017. 222 Oregon Office of Emergency Management, “Communicating during & after emergencies,” Webpage. 223 Oregon.gov, “2 Weeks Ready,” Webpage. 224 Eric Holdeman, “Hawaii Opts for 14 Days Preparedness,” Emergency Management, August 22, 2018; HI-EMA, 2 Weeks Ready Brochure, August 

2018. 

225 HI-EMA, “Hawaii Hazards Awareness and Resilience Program (HHARP),” Webpage. 
65 

II. National Institute of Standards and Technology Community 

Resilience Program

NIST has been working on developing community resilience planning and related guidance tools designed to 

be community-driven and incorporated into existing efforts for a number of years. Part of this effort is the 

NIST Community Resilience Program, which began in 2014 in response to several large-scale disasters.226

The program is designed to:227

1. Develop science-based tools and metrics to support and measure resilience at the community level

and support economic evaluation of alternative solutions to improve resilience. 

2. Engage community resilience stakeholders for feedback for products, such as guidance, tools, and 

metrics, for planning and implementing resilience measures. 

3. Learn from events that have impacted the built environment to better understand adverse hazard 

impacts on communities and develop improved tools and methods for field studies.

The program is meant to be locally led. The community resilience planning and related guidance tools, 

including economic decisions guides and community resilience planning guides, are designed to be 

community-driven and incorporated into existing efforts.

228 Through the guidance, communities can 

establish collaborative planning teams who do the bulk of the work, and engage a larger stakeholder 

network to inform the process.

To emphasize that the program’s solutions are not imposed on a community, but rather developed 

consistently with a community’s capacity to build, maintain, and operate over time, NIST is initiating a 

program called the Community Resilience Panel.

229 Because engagement across the community is key to

ensure all stakeholders are bought into the process and its end result, this panel within communities will

promote collaboration among stakeholders to strengthen the resilience of buildings, infrastructure, and 

social systems upon which communities rely.230 Cities, counties, and communities need to define what 

resilience should look like for them, such as determining their unique critical functions or locating vulnerable 

populations. NIST’s approach is to develop tools that can be implemented locally to help develop the 

capacity at the local levels. 

The first major deliverable of the Community Resilience Program was the Community Resilience Planning 

Guide for Buildings and Infrastructure Systems report, released in 2015.231 The Guide offers a six-step 

process to develop community resilience containing resilience plans that drive or complement ongoing 

resilience improvement planning across communities. Since the Guide’s release, several communities have 

begun to use it to develop resilience plans. Some examples include:232

• Fort Collins, Colorado used the Guide to address government, education, healthcare, and 

community service organizations that provide shelter during emergencies.

 

226 NIST, “Community Resilience Program,” Webpage. 227 Ibid. 228 Ibid. 229 Ibid. 230 Ibid. 231 Stephen A. Cauffman, Community Resilience Planning Guide for Buildings and Infrastructure Systems: Observations on Initial Implementations. 

NISTIR 8229, September 2018.

232 Ibid. 
66 

• Delaware Department of Transportation (DelDOT) used the Guide to support two highway corridor 

assessments and as a reference in the development of Maryland’s Strategic Implementation Plan for 

Climate Change, Sustainability, and Resilience for Transportation.233

• Howard County, Maryland used the NIST Guide as a reference during the process of developing a 

recovery plan for the county. 

NIST has also done work to identify building clusters or the buildings within communities that provide 

crucial services or functions.234 Every building and infrastructure system is not needed immediately 

following a hazard event. The time needed to achieve community recovery depends on the extent of 

damage, the overall physical and mental health of the community, dependencies between systems, the 

characteristics of the community’s economy, the governance structure, and the availability of financial 

resources. Therefore, it is important that these factors be known and understood across a community to 

support recovery.235 Setting specific performance goals for building clusters in communities will shape the 

sequence of recovery activities for their built environment and identify dependencies between systems. This 

can help communities identify sheltering capacity and other needs.236

 

233 Delaware DOT, Strategic Implementation Plan for Climate Change, Sustainability & Resilience for Transportation, July 2017. 234 NIST, Guide Brief 11 – Determining Building Cluster Performance Goals, NIST Special Publication 1190GB-11. 235 Ibid. 236 Ibid. 
67 

Appendix G: Lessons Learned from 2017 Disasters

During the course of the study, the nation experienced a number of severe disasters causing loss of life, 

destruction of communities, and billions of dollars in damage. The federal government, state, local, tribal, 

and territorial (SLTT) governments, and utilities currently have robust systems and processes in place to 

respond to disasters we have previously experienced (e.g., hurricanes) even if an event is more severe than 

those previously experienced. These entities continue to learn from each event and incorporate the 

experiences and knowledge to improve preparedness and response for similar future disasters. 

This study did not focus on preparedness, response, and recovery from hurricanes, wildfires, and other 

disasters; rather it focused on events beyond modern experience. However, the lessons learned from prior 

events, including the disasters that took place in 2017 and 2018, provided the NIAC with a better 

understanding of current response plans and the challenges that the nation may face in a catastrophic 

power outage. This appendix provides a high-level overview of the information most relevant to this study, 

and should not be considered a comprehensive summary of the disasters and their impact, or lessons 

learned. 

I. Overview of the 2017 Disasters

In 2017, four near-sequential disasters—Hurricane Harvey, Hurricane Irma, Hurricane Maria, and the 

California wildfires—created an unprecedented demand for federal disaster response and recovery 

resources.237 It was the most active hurricane season since 2005, and was the seventh most active season in 

historical record dating back to 1851.238 The 2017 hurricanes and wildfires collectively affected 47 million 

people—nearly 15 percent of the nation’s population.239 The cumulative cost to the U.S. was $306.2 billion, 

breaking the previous cost record of $214.8 billion from 2005.240 Specifically, 2017 had 17 named storms, 10 

of which became hurricanes, including 6 major hurricanes (Category 3, 4, or 5);

241 the strongest Atlantic 

Ocean hurricane on record with winds peaking at 185 mph (Hurricane Irma); 71,499 wildfires;

242 and a 

greater amount of Department of Defense (DOD) contracts and mission assignments for the response to the 

California wildfires than the hurricane response in support of Texas and Florida combined.

243

A. Puerto Rico

In September 2017, Hurricane Irma caused significant damage to Puerto Rico, leaving over a million 

residents without power. Before the island could move from response to recovery efforts, Hurricane Maria 

further damaged and caused widespread failure to the island’s power grid, resulting in the longest power 

restoration mission in U.S. history.244 It is also the largest and longest federal response to a domestic 

disaster, including being the longest air mission for Federal Emergency Management Agency (FEMA), the 

largest medical response ever, and the largest power restoration mission.

245

 

237 GAO, “2017 Hurricanes and Wildfires,” September 2018. 238 NOAA, “Extremely Active 2017 Atlantic Hurricane Season Finally Ends,” November 30, 2017. 239 FEMA, 2018-2022 Strategic Plan, 2018. 240 NOAA, “Hurricane Costs,” Last modified October 17, 2018. 241 NOAA, “Extremely Active 2017 Atlantic Hurricane Season Finally Ends,” November 30, 2017. 242 NIFC, “Total Wildland Fires and Acres (1926-2017), Webpage. 243 FEMA, 2018-2022 Strategic Plan, 2018. 244 Rhodium Group, “America’s Biggest Blackout,” 2018. 245 FEMA, “Puerto Rico One Year after Hurricanes Irma and Maria,” Press release, September 6, 2018. 
68 

In the immediate aftermath, more than 80 percent of the island’s power lines were knocked down in the 

Category 4 winds—uprooting much of Puerto Rico’s infrastructure and leaving all 3.6 million residents 

without power and 90 percent of cell towers were out of service.246 Almost full power was restored to the 

entire island 11 months after Hurricane Maria hit, with 

only small pockets of outages due to geography 

constraints or the need for new transmission lines.247

There were cascading second-, third-, and fourth-tier 

effects stemming from the loss of power. Water pumps 

shut off248 and water testing labs were affected, causing 

further delays in accessing safe, potable water.249

Damage to pharmaceutical manufacturing facilities 

caused a shortage of saline IV bags across the United 

States.250 With no way to keep money flowing, the 

Treasury Department sent $250,000 in cash to allow 

commerce to continue on the island.

Puerto Rican officials initially announced that 64 people 

died as a result of Hurricane Maria.251 A 2018 study 

reported that the estimate was much higher at 2,975 

people.252

 

2018 Disasters 

This year also brought a number of severe storms 

and disasters: 

• The 2018 hurricane season was the most 

active recorded for Pacific Ocean storms with 

Hurricanes Lane, Rosa, Sergio, and Willa. 

• Hurricane Florence had the second highest 

rainfall after Hurricane Harvey, causing an 

estimated $13 billion in damages.

• Hurricane Michael was the most powerful 

storm to hit the Florida Panhandle on record. 

• The Camp Fire was the deadliest and most 

destructive fire in California history. It 

destroyed 18,000 structures, burned 153,000

acres, and killed 86 people. 

• The Mendocino Complex fire that began in 

July 2018, was the largest recorded fire in 

California, burning 459,123 acres. 280 

structures were destroyed, including 157 

residences, killing a firefighter and injuring

four others. 

Source: The Washington Post, Sept. 19; ABC 13 

Eyewitness News, November 19; ABC 11 Eyewitness 

News, Sept. 26; UPI, Dec. 12

II. Lessons Learned

As discussed throughout the report, the federal 

government, SLTT governments, and utilities 

continuously look for ways to improve emergency 

preparedness and response, whether from exercises or 

actual events. This section includes insights gathered 

during interviews and from after-action reports. 

A. Utility Lessons Learned

The 2017 hurricanes reinforced that there is no easy or one-size-fits-all solution. In most cases, mutual 

assistance continues to be an effective way for utilities to quickly and efficiently restore service, but this can 

be dependent on geography and company structures. The prepositioning of resources and working closely 

with SLTT and federal partners also helps utilities respond more efficiently. Investments in infrastructure 

hardening and system modernization ahead of a disaster can help reduce the impact and/or speed of 

restoration. Other lessons learned include: 

246 FCC, Communications Status Report for Areas Impacted by Hurricane Maria, September 27, 2017. 247 Jessica Resnick-Ault, “Puerto Rico finally restored power to the entire island – 328 days after Hurricane Maria hit,” Business Insider, August 15, 

2018. 

248 John Humphrey, “7 Things About Life in Puerto Rico with No Electricity,” IEEE Spectrum, December 4, 2017. 249 Sara Reardon, “Puerto Rico struggles to assess hurricane’s health effects,” Nature, November 15, 2017. 250 Sarah Baker, “Are we doing enough to protect the health care supply chain?” The Hill, March 30, 2018. 251 Puerto Rico Public–Private Partnerships Authority, An Economic and Disaster Recovery plan for Puerto Rico, July 9, 2018. 252 Milken Institute School of Public Health, George Washington University, Ascertainment of the Estimated Excess Mortality From Hurricane Maria in 

Puerto Rico, 2018.
69 

• Fast and efficient restoration is dependent on prior training, established mutual assistance 

agreements, and investments in new technology. For example, before, during, and after Hurricane 

Harvey, CenterPoint—an energy utility covering a 5,000 square-mile service territory in the Houston 

metropolitan area—mustered resources; created staging sites; and transported, housed, and fed 

the people needed for response and restoration (approximately 3,500 resources).253 Over the 

course of the 5-day event, more than 1 million customers lost power, but CenterPoint experienced 

only 200,000 people without power at any one time. 

• The use of smart meters enabled constant metering and outage tracking during and after the 

storm. When crews were unable to go into the field after the storm, meters provided constant 

power updates, enabling power utilities to accurately report to customers, the media, regulators, 

and legislators about outages and power restoration in real-time, sometimes through social media. 

This type of response is dependent on working communications. 

• Investments in hardening before a disaster make a difference. For example, Florida Power and 

Light (FPL) spent billions to harden its infrastructure following the 2004 hurricane season when it 

experienced four hurricanes in 44 days (Hurricanes Charley, Frances, Ivan, and Jeanne).254 FPL 

worked with regulators and conducted outreach with customers as part of the process. 

o Hurricane Irma was a Category 4 storm, which was 1.5 times stronger than a previously 

devastating storm that caused an average of 8 days until power restoration. After Hurricane 

Irma, the average FPL customer in Florida had power back after 5 days, the fastest 

restoration of the largest amount of people by one utility in U.S. history,

255 and three days 

faster than the national average for that event. For the service territory, every day 

customers are without power results in $1 billion of economic loss. Those three days 

prevented $3 billion of economic loss. 

B. FEMA Lessons Learned

In its 2017 Hurricane Season After-Action Report, FEMA found that the 2017 hurricanes and wildfires 

highlighted some longstanding issues and revealed other emerging response and recovery challenges. For 

example, the concurrent timing and scale of the disaster damages nationwide caused shortages in available 

debris removal contractors and delays in removing disaster debris—a key first step in recovery. In addition, 

FEMA’s available workforce was overwhelmed by the response needs.256

During the 2017 response, a Power Task Force—with representatives from FEMA, Department of Energy 

(DOE), U.S Army Corps of Engineers (USACE), the private sector, and local government—was stood up to 

discuss ongoing issues and serve as an operational team during an event as a way to respond more 

effectively and efficiently. The after-action report highlighted the need to continue this collaborative, steady 

state partnership. 

FEMA also incorporated lessons learned from 2017 into its 2018-2022 Strategic Plan, which outlines the

agency’s path forward for improving emergency response. One of the key lessons learned FEMA highlighted 

is that the most effective strategy for emergency management is when it is federally supported, state 

 

253 Center Point, “Where we serve,” Webpage. 254 David Fleshler, “Taken by Storm,” Sun Sentinel, August 8, 2014. 255 “FPL completes service restoration to more than 4.4 million customers impacted by historic Hurricane Irma,” Press release, September 22, 2017. 256 GAO, “2017 Hurricanes and Wildfires,” September 2018. 
70 

managed, and locally executed.257 As mentioned in Appendix D, FEMA identified 3 strategic goals and 12 

supporting objectives to guide efforts in the coming years. Other lessons learned include: 

• All levels of governments need to be better prepared with their own supplies, have prepositioned 

contracts with enforcement mechanisms, and be ready for the economic effects of a disaster. This 

includes developing a better understanding of local, regional, and national supply chains, form

stronger relationships with critical private sector partners.258

• Flexible authorities and programs are important since response requires adaptation, because 

disasters do follow plans. For example, FEMA’s plans did not anticipate the massive requirements 

to directly assist electricity, telecommunications, and fuel sector utilities with air and sea movement

for response and recovery efforts in Puerto Rico. FEMA needs to support states to build a greater 

capacity to respond to small-scale events, without an oversized federal response, by providing 

financial assistance to state-managed disasters.

259

• Critical infrastructure owners and operators, and state and local governments, should be 

encouraged to invest in more resilient infrastructure. This includes investment in pre-disaster 

mitigation opportunities, such as up-to-date building codes and hurricane-resilient building 

materials.260 Investments in hardening infrastructure and ensuring it is well-maintained can help 

reduce the severity of storm impacts and help areas recover and restore power faster.

• Private companies working collaboratively can make a huge impact in response and recovery 

efforts. A lack of knowledge or awareness about interdependencies and cascading effects can delay 

response and recovery. The private sector, which has a greater knowledge of day-to-day operational 

needs, should be engaged from the beginning. For example, in Puerto Rico, the power outage 

caused water pumps to shut off261 and water testing labs to lose power, which caused further delays 

in accessing safe, potable water.262

• Mutual aid contracts should be established prior to an event, with details such as cost and timing 

decided ahead of time, so recovery and restoration can begin without delays. Standardized 

contracts should be integrated under one umbrella that is applicable across states and the public 

and private sectors. For example, New York already has this type of contract between states, which 

is why after Superstorm Sandy, resources were organized more efficiently for response and recovery 

efforts.

263

• Federal coordination with other federal, local, and volunteer emergency partners before an event 

occurs cuts down on response time. FEMA coordinated closely with Texas, Florida, and California 

emergency management officials and other federal, local, and volunteer emergency partners to 

implement emergency preparedness actions prior to the 2017 disasters. This helped overcome a 

number of challenges such as deploying a sufficient and adequately-trained disaster workforce and 

removing debris in a timely manner after the 2017 hurricanes and wildfires cutting down on the 

overall time for response.

264

 

257 FEMA, 2018-2022 Strategic Plan, 2018. 258 Ibid. 259 Ibid. 260 Ibid. 261 John Humphrey, “7 Things About Life in Puerto Rico with No Electricity,” IEEE Spectrum, December 4, 2017. 262 Sara Reardon, “Puerto Rico struggles to assess hurricane’s health effects,” Nature, November 15, 2017. 263 DOE, Overview of response to Hurricane Sandy – Nor’easter and recommendations for Improvement, February 26, 2013. 264 GAO, “2017 Hurricanes and Wildfires,” September 2018. 
71 

C. Looking Ahead

While communities continue to recover from these events, FEMA has already started implementing its 

recommendations from the after-action report and its strategic plan. One such recommendation is the 

update to the National Response Framework (NRF) to focus more on critical lifelines and cross-sector 

coordination. (See Appendix D for more information). 
72

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