U.S. GOVERNMENT PUBLISHING OFFICE

26–072 WASHINGTON : 2018

S. HRG. 115–284 

THE THREAT POSED BY ELECTROMAGNETIC 

PULSE AND POLICY OPTIONS TO PROTECT 

ENERGY INFRASTRUCTURE AND TO IMPROVE 

CAPABILITIES FOR ADEQUATE SYSTEM RESTORATION 

HEARING 

BEFORE THE 

COMMITTEE ON 

ENERGY AND NATURAL RESOURCES 

UNITED STATES SENATE 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

MAY 4, 2017 

( 

Printed for the use of the 

Committee on Energy and Natural Resources 

Available via the World Wide Web: http://www.govinfo.gov 
(II) 

COMMITTEE ON ENERGY AND NATURAL RESOURCES 

LISA MURKOWSKI, Alaska, Chairman 

JOHN BARRASSO, Wyoming 

JAMES E. RISCH, Idaho 

MIKE LEE, Utah 

JEFF FLAKE, Arizona 

STEVE DAINES, Montana 

CORY GARDNER, Colorado 

LAMAR ALEXANDER, Tennessee 

JOHN HOEVEN, North Dakota 

BILL CASSIDY, Louisiana 

ROB PORTMAN, Ohio 

LUTHER STRANGE, Alabama 

MARIA CANTWELL, Washington 

RON WYDEN, Oregon 

BERNARD SANDERS, Vermont 

DEBBIE STABENOW, Michigan 

AL FRANKEN, Minnesota 

JOE MANCHIN III, West Virginia 

MARTIN HEINRICH, New Mexico 

MAZIE K. HIRONO, Hawaii 

ANGUS S. KING, JR., Maine 

TAMMY DUCKWORTH, Illinois 

CATHERINE CORTEZ MASTO, Nevada 

COLIN HAYES, Staff Director 

PATRICK J. MCCORMICK III, Chief Counsel 

ISAAC EDWARDS, Senior Counsel 

ANGELA BECKER-DIPPMANN, Democratic Staff Director 

SAM E. FOWLER, Democratic Chief Counsel 

DAVID GILLERS, Democratic Senior Council 

RICH GLICK, Democratic General Counsel 
(III) 

C O N T E N T S 

OPENING STATEMENTS 

Page 

Murkowski, Hon. Lisa, Chairman and a U.S. Senator from Alaska .................. 1 

Cantwell, Hon. Maria, Ranking Member and a U.S. Senator from Washington .................................................................................................................... 3 

WITNESSES 

LaFleur, Hon. Cheryl, Acting Chairman, Federal Energy Regulatory Commission ........................................................................................................................ 5 

Gingrich, Hon. Newt, Chairman of the Board, Gingrich Productions ................. 15 

Cooper, Ambassador Henry F., Former Director, Strategic Defense Initiative 

Organization ......................................................................................................... 19 

Durkovich, Caitlin, Director, Toffler Associates .................................................... 32 

Manning, Robin E., Vice President, Transmission and Distribution, Electric 

Power Research Institute .................................................................................... 39 

Wailes, Kevin, Chief Executive Officer, Lincoln Electric System, and Member 

of the Board of Directors, American Public Power Association ........................ 49 

ALPHABETICAL LISTING AND APPENDIX MATERIAL SUBMITTED 

Brumley, Dr. David: 

Response to Questions for the Record ............................................................. 114 

Cantwell, Hon. Maria: 

Opening Statement ........................................................................................... 3 

Cooper, Ambassador Henry F.: 

Opening Statement ........................................................................................... 19 

Written Testimony ............................................................................................ 21 

Responses to Questions for the Record ........................................................... 93 

Durkovich, Caitlin: 

Opening Statement ........................................................................................... 32 

Written Testimony ............................................................................................ 34 

Responses to Questions for the Record ........................................................... 102 

Gingrich, Hon. Newt: 

Opening Statement ........................................................................................... 15 

Written Testimony ............................................................................................ 17 

Responses to Questions for the Record ........................................................... 92 

LaFleur, Hon. Cheryl: 

Opening Statement ........................................................................................... 5 

Written Testimony ............................................................................................ 8 

Responses to Questions for the Record ........................................................... 80 

Manning, Robin E.: 

Opening Statement ........................................................................................... 39 

Written Testimony ............................................................................................ 41 

Responses to Questions for the Record ........................................................... 105 

Murkowski, Hon. Lisa: 

Opening Statement ........................................................................................... 1 

Wailes, Kevin: 

Opening Statement ........................................................................................... 49 

Written Testimony ............................................................................................ 51 

Responses to Questions for the Record ........................................................... 109 

(1) 

THE THREAT POSED BY ELECTROMAGNETIC 

PULSE AND POLICY OPTIONS TO PROTECT 

ENERGY INFRASTRUCTURE AND TO IMPROVE CAPABILITIES FOR ADEQUATE SYSTEM RESTORATION 

THURSDAY, MAY 4, 2017 

U.S. SENATE, COMMITTEE ON ENERGY AND NATURAL RESOURCES, Washington, DC. 

The Committee met, pursuant to notice, at 10:09 a.m. in Room 

SD–366, Dirksen Senate Office Building, Hon. Lisa Murkowski, 

Chairman of the Committee, presiding. 

OPENING STATEMENT OF HON. LISA MURKOWSKI, 

U.S. SENATOR FROM ALASKA 

The CHAIRMAN. Good morning. The Committee will come to 

order. 

I would like to welcome everyone to the Energy hearing this 

morning. We are here to examine the threat that is posed by electromagnetic pulse, that is known as EMP, as well as policy options 

to protect energy infrastructure and provide for system restoration 

in the event of an EMP attack. The United States has recognized 

a potential EMP attack as a national security threat for decades 

and our efforts to understand a potential EMP burst are certainly 

not new. 

The Department of Defense (DoD) and our national labs have 

been grappling with these issues to one degree or another since we 

first started testing nuclear weapons. Extensive tests in the 1950s 

and 60s examined the potential impact of an EMP burst on both 

military and civilian infrastructure. Today, however, there is a renewed focus on understanding the effects of such an attack and an 

increase of efforts directed at mitigating and recovering from such 

an event should it occur. This issue is, perhaps, more salient now 

than ever for several compelling reasons. 

First is the proliferation of nuclear technology which is no longer 

limited to the U.S., Russia, China, the U.K. and France. Other nations have tested nuclear weapons and missiles to deliver them. 

Rogue nations, such as North Korea, may already have or be close 

to obtaining these capabilities. We must also be mindful of the potential for a non-state actor to obtain a nuclear device. While their 

ability to use a missile as a delivery vehicle for a high altitude 

EMP attack would likely be more limited, we know that it cannot 

be ruled out. 
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Second is the proliferation of electronics in today’s society. Just 

about everyone in this room, I would venture to say, has a 

smartphone. That is just the start of the devices that we rely on, 

and that, in turn, rely on electricity and electronics to function. 

This has magnified the impact as compared to the potential impact 

in the 1960s that an EMP burst could now have on the electric 

grid, the technologies that rely on electronics and on our daily 

lives. 

We must recognize from the start of today’s discussion that the 

threat posed by an EMP attack is a matter of national defense. Defending our nation from a missile carrying a nuclear warhead is 

clearly beyond the scope of the owners and operators of energy infrastructure and their regulators. Nevertheless, these institutions 

do have a role in protecting critical energy infrastructure and providing for its restoration. As the owners and operators of critical 

energy assets, our utilities must assist government EMP experts in 

understanding how the electric grid works. 

For its part, government must prudently share its knowledge and 

expertise with industry on a timely basis and approve or direct 

prudent, reliability standards as warranted. There really is no way 

around this. 

On the one hand, we have defense and national security personnel who are very familiar with the effects of a nuclear detonation but who are not responsible for the complexities of keeping the 

lights on. And on the other hand, you have professionals in the 

power sector who know the grid but are not familiar with the characteristics of a nuclear detonation. 

It is critical that the electric industry and government improve 

upon their mutual understanding and trust because it is essential 

to the productive relationships that are necessary to improve our 

ability to respond to EMP and other potential, high impact, but low 

frequency events. 

Both camps must work together to share information and expertise. Our engineering schools and other conduits for professional 

expertise must embrace a new paradigm for considering and addressing security threats in the design and operation of electric systems. 

Improving our ability to respond to an EMP threat is also an 

area where, like cybersecurity, the subject of another recent hearing that we just had, stronger public/private partnerships are needed and today’s capabilities must be improved. This hearing will 

consider as a policy matter whether the appropriate federal agencies have the authority they need to address this potential threat 

and whether additional authority or direction is needed. 

Back in 2005, we established authority for the North American 

Electric Reliability Corporation, now NERC, through an informed 

stakeholder process to establish, subject to the Federal Energy Regulatory Commission’s (FERC) approval, mandatory, physical and 

cybersecurity standards for the industry. More recently, in 2015, 

Congress codified the Department of Energy (DOE) as the sectorspecific agency for energy critical infrastructure and provided the 

Secretary with emergency authority to address a host of threats: 

cyber, physical, geomagnetic disturbances and EMP. So we have 

taken some steps, but many argue and believe that those steps are 
3 

not sufficient and that we still have a great deal of work in this 

area. 

Our task today is to consider the distinct points of view about 

EMP brought to us this morning by our very distinguished panel. 

I am looking forward to the testimony we will receive from each of 

you. 

I now turn to my Ranking Member, Senator Cantwell. 

STATEMENT OF HON. MARIA CANTWELL, 

U.S. SENATOR FROM WASHINGTON 

Senator CANTWELL. Thank you, Madam Chair. 

I welcome the witnesses here today and thank you for scheduling 

this hearing. 

The electric grid is essential to our lives and also the lifeblood 

of our economy. With the fate of our economy dependent on access 

to reliable electricity, it is our responsibility to ensure that the grid 

is prepared to withstand many threats including natural disasters, 

including those caused by changes in climate, extreme weather, 

physical attacks of terrorism, cyberattacks, geomagnetic disturbances, electromagnetic pulse, or EMP. We must continue to identify 

and evaluate the threats to the system as well as appropriate investments in technology to reduce these threats. 

Threats to the grid are measured both by probability and severity of impact. We must prepare and protect against all these hazards, but we must prioritize based on the likelihood of occurrence 

and severity of impact. 

Electromagnetic pulse attacks are considered a high-impact, lowprobability threat, as I think, Mr. Manning, in his testimony, indicates. We do not yet have the concrete science-based analysis necessary to understand the threat and identify effective solutions. 

As a result, in 2001 Congress established a commission to assess 

the threat from high-altitude electromagnetic pulse, known as 

HEMP. In 2014, the Department of Homeland Security (DHS) developed guidelines to help federal agencies identify those options to 

protect critical equipment and facilities and communication and 

data centers from these attacks. 

The Department of Energy and the Electric Power Research Institute (EPRI) are both engaged in studying the EMP threat and 

releasing action plans for both government and private industry. 

The Departments of Homeland Security, Defense and Energy, including our national labs, are actively engaged in studying the effects of EMP and identifying proactive measures that can help 

mitigate against these threats. 

As Mr. Manning has noted, solutions to EMP threats to the grid 

are not well understood. Much of the available information is not 

specifically applied to utilities, making it difficult for utilities and 

regulators to identify the options for protecting that infrastructure. 

So I am pleased the work is currently underway by both industry 

and the government to identify our options. 

I also want to say that threats to our grid are measured by the 

likelihood of occurrence and severity and warming climate has increased physical threats to our infrastructure with rising sea levels, storm surge and extreme weather events. According to NOAA, 

high sea surface temperatures have contributed to a substantial in-
4 

crease in hurricane activity in the Atlantic and the severity of 

those strong threats on our grid. 

In 2012, Hurricane Sandy tore through the East Coast leaving a 

path of wreckage, rainfall, and knocked down power lines, leaving 

88.5 million homes and businesses in 16 states without power. 

In the State of Washington, we have seen extreme weather 

changes. We have had landslides, flooding and sea level rise, as 

well as drought, that has induced forest fires threatening our grid. 

In 2014, large fires in Central Washington substantially impacted 

the electric infrastructure with over 3,000 customers without 

power. I should say that the cost is how much was actually burnt 

up in the fire, substantive investments that had just been made by 

utilities in that region. 

Finally, I would like to talk about the issue of cybersecurity that 

the Chair mentioned. While we have never experienced a high-altitude EMP attack, the severity of successful cyberattacks on our 

grid is growing and it is significantly more likely that our grid is 

being tested for cyber vulnerabilities every day by our adversaries. 

In fact, Russia is believed to have deployed a cyber weapon to shut 

down Ukraine’s grid in both 2015 and 2016. 

On March 14th of this year I asked the Trump Administration 

to protect the growing grid vulnerabilities from cyberattacks and 

make sure that we zero in on the appropriate assets. I sent a letter 

to the Administration and to the Department of Energy asking that 

they assess the capabilities of some of these nations, of Russians, 

particularly, to hack into our energy infrastructure, and I am looking forward to getting a response since it has been several weeks 

since we sent that letter. 

It is widely known the United States is under constant threat 

from cyberattacks, and many cyber experts have come to the same 

conclusion. It is not an if, but a when, a massive attack on our grid 

will occur. In fact, the former Director of National Intelligence, 

General Clapper, stated in 2015 that cybersecurity is now more a 

significant threat to our national security than terrorism. 

So I am glad we are holding this hearing on the risks to our grid, 

and EMP being one of them, but I hope that we will also make sure 

that we continue to focus on cybersecurity. I know we have had a 

hearing, and three other committees that I serve on have also had 

cybersecurity hearings. 

I think everybody is waking up to the fact that cyber is a big 

issue. Obviously, Madam Chair, we passed the Energy Policy Modernization Act out of the Senate, that the House failed to act on, 

which had a major cybersecurity provision. So I hope our colleagues 

over there will wake up to the importance of that. 

I look forward to hearing from our witnesses. And thank you, 

Madam Chair, for the hearing. 

The CHAIRMAN. Thank you, Senator Cantwell. 

We are joined this morning by a very distinguished panel. I welcome you all. 

The panel will be led off this morning by the Honorable Cheryl 

LaFleur, who is the Chairman of the Federal Energy Regulatory 

Commission. She has been a member of the FERC since 2010. We 

appreciate all that you do on that very important commission. We 
5 

would like to get you a quorum so that you can be working every 

day, but we are pleased that you are here this morning. 

Chairman LaFleur will be followed by a man who is well known 

up here on Capitol Hill. It is a pleasure to welcome you to the Committee. Chairman of the Board of Gingrich Productions and former 

Speaker of the House, Speaker Gingrich has been a leading voice 

on the issues and the dangers of an EMP attack. We are very 

pleased to have you provide your insight this morning. 

Following Speaker Gingrich is Ambassador Henry Cooper. He is 

the former Director of the Strategic Defense Initiative Organization, and he was President Reagan’s Chief Negotiator at the Geneva Defense and Space talks. It is nice to have you at the Committee this morning. Welcome. 

Caitlin Durkovich is the Director at Toffler Associates. Prior to 

joining Toffler, she served as the Assistant Secretary for Infrastructure Protection with the Department of Homeland Security under 

President Obama. It is nice to have you here. 

Mr. Robin Manning currently serves as the Vice President of 

Transmission and Distribution at the Electric Power Research Institute, EPRI, where he oversees research and development activities. We thank you for your leadership there. 

The panel will be rounded out by Mr. Kevin Wailes, who serves 

as the CEO and Administrator of Lincoln Electric System. Mr. 

Wailes is also the Vice Chair of the Electricity Subsector Coordinating Council. 

We are pleased to have you all here. We would ask that you try 

to limit your comments to five minutes. Your full statements will 

be included as part of the record. Commissioner LaFleur, if you 

would like to lead off, please. 

STATEMENT OF HON. CHERYL LAFLEUR, ACTING CHAIRMAN, 

FEDERAL ENERGY REGULATORY COMMISSION 

Ms. LAFLEUR. Good morning and thank you, Chairman Murkowski, Ranking Member Cantwell and members of the Committee. I appreciate the opportunity to appear before you today to 

discuss electromagnetic pulse, EMP, threats to the electric grid in 

the United States. I very much appreciate your attention to this 

important issue. 

The Federal Energy Regulatory Commission, FERC, plays a key 

role in the oversight of grid reliability. In 2005, Congress entrusted 

FERC with the responsibility to approve and enforce mandatory reliability standards for the nation’s bulk power system. Under the 

statute, FERC oversees the North American Electric Reliability 

Corporation, NERC, in developing standards to protect the reliability and security of the grid. 

In addition to our work on mandatory standards, FERC has also 

supported grid security through collaborative efforts with federal 

agencies, states, industry and stakeholders. This work is particularly well suited to revolving threats that require action more 

quickly than a standard can be written. And as Senator Murkowski 

noted, public/private communication on those threats is critical. 

FERC, NERC and industry have, over the last decade, put in 

place a robust set of baseline standards to address a wide range 

of reliability issues. In recent years, we’ve been particularly focused 
6 

on emerging threats to grid security, including cybersecurity, physical security and the risk associated with geomagnetic disturbances. 

Geomagnetic disturbances to the bulk power system can be 

caused in two different ways: naturally occurring geomagnetic disturbances (GMDs) from solar activity and man-made EMP events. 

EMPs can be generated by devices that range from small, portable suitcase units all the way through detonation of nuclear weapons in the upper atmosphere. EMP devices can generate three distinct effects: a short, high energy burst, called E1, that can destroy 

electronics; a slightly longer burst that is similar to lightning 

termed E2; and a third effect, E3, that generates electric currents 

in power lines and equipment which can then damage equipment 

such as transformers. 

In the case of GMDs, naturally occurring solar magnetic disturbances periodically disrupt the Earth’s magnetic field which in turn 

can induce currents on the electric grid that may cause voltage instability or destroy key transformers over a large geographic area. 

GMD events are similar in character and effect to the final phase 

of EMP, E3. 

I’ll briefly touch this morning on some of the work FERC has 

done that can help address EMP. 

First, FERC developed the directed, excuse me, FERC directed 

the development of standards on GMD that can help to mitigate 

the E3 effective EMP based on a 1 in 100 years’ solar storm benchmark event. Second, FERC directed the development of a physical 

security standard, like the GMD standard now effective and in 

place, that can help protect against attack from small, portable 

EMP devices which require proximity to their intended targets. 

Third, FERC has supported efforts to protect the grid, the resilience of the grid, against all risks which improves its ability to respond and recover from major outage events whatever the cause. 

For example, mandatory reliability standards require backup capabilities for the loss of critical assets which reduces the potential 

for cascading outages. FERC has also issued orders concerning grid 

assurance and EEIs, spare transformer equipment program, which 

are efforts to protect customers from prolonged outages by providing electric utilities timely access to emergency transmission 

equipment that otherwise would take months or longer to acquire. 

As I expect we will discuss today, FERC has not to date directed 

NERC to develop a specific standard specifically targeting EMP. To 

be clear, I believe this is the result of recent consideration of the 

issue, not a lack of attention or willingness by FERC to address 

EMP threats. Although much work has been done, there remains 

a significant amount of scientific research and debate underway 

about how EMP, particularly the E1 component, affects the electric 

grid. 

I particularly want to highlight the work being done by DOE, Los 

Alamos National Lab, Idaho National Lab, an amazing place I visited a couple years ago, DHS and the Electric Power Research Institute, which I believe will help improve our understanding of 

EMP impacts on the electric grid and more importantly, how best 

to target our actions to mitigate them. 
7 

FERC is closely engaged in all these efforts to understand and 

address the EMP threat as more fully detailed in my written testimony. Those efforts will and must continue, and I’m confident that 

should FERC determine that a reliability standard is warranted, it 

will exercise its authority to require one as it has with other 

threats, like GMD and physical security. 

Thank you for the opportunity to testify, and I look forward to 

your questions. 

[The prepared statement of Ms. LaFleur follows:] 
8 

Testimony of Cheryl LaFleur 

Acting Chairman, Federal Energy Regulatory Commission 

Before the Committee on Energy and Natural Resources 

United States Senate 

May 4, 2017 

Chairman Murkowski, Ranking Member Cantwell, and Members of the 

Committee: 

Thank you for the opportunity to appear before you today to discuss 

electromagnetic pulse (EMP) threats to the electric grid in the United States. I 

appreciate the Committee's attention to this important issue. 

The Federal Energy Regulatory Commission (FERC) plays a central role in 

protecting the reliability of the Nation's electric grid against a range of threats, both 

naturally-occurring and manmade. Our work generally takes the form of both 

mandatory reliability standards and voluntary, collaborative efforts with our federal 

and state colleagues, industry, and other stakeholders. Before turning to EMP 

specifically, I would like to provide an overview of the evolution ofFERC's reliability 

work, which I believe will help inform that discussion. 

FERC's Oversight of Grid Reliability 

In the Energy Policy Act of 2005, Congress entrusted FERC with a new 

responsibility to approve and enforce mandatory reliability standards for the Nation's 

bulk-power system. This authority is found in section 215 of the Federal Power Act 

(FPA), and is limited to the "bulk-power system," as defined in the statute, which 

excludes Alaska and Hawaii, as well as local distribution systems. 

Under FPA section 215, FERC cannot directly write or modify reliability 

standards but must rely on the Electric Reliability Organization (ERO) that FERC 

certifies to perform this task. In 2006, FERC certified the North American Electric 

Reliability Corporation (NERC) as the ERO. Under the section 215 construct, NERC 

develops and proposes for FERC's review new or modified reliability standards. In 

addition, as I will discuss in more detail below, FERC may direct NERC to develop 

or modify a standard and has done so when FERC determines that new or modified 

standards are needed. Once NERC develops a standard, it is filed with FERC, at 

which time FERC can either approve or remand the standard. If FERC approves a 

proposed standard, it becomes mandatory and enforceable in the continental United 

States and is applicable to the users, owners and operators of the bulk-power system. 

IfFERC remands a proposed reliability standard, it is sent back to NERC for further 

consideration. 
9 

In addition to its formal standards work, FERC has also supported grid security 

through voluntary and collaborative efforts. Largely conducted by FERC's Office of 

Energy Infrastructure Security, FERC has worked closely with other federal agencies, 

states, industry, and other stakeholders to improve coordination and knowledgesharing regarding threats to the grid. This work includes, among other activities, the 

development, identification, and dissemination of best practices; participation in grid 

reliability exercises; and providing briefings to state colleagues. 

FERC, NERC, and industry have made significant progress over the last 

decade to put in place a robust set of baseline standards to address basic day-to-day 

grid reliability issues, like tree trimming and relay setting. Reaching a steady state on 

those standards has allowed us to increasingly shift our attention to cutting edge or 

emerging threats, like cyber and physical security of critical grid infrastructure, and 

the risks associated with geomagnetic disturbances (GMD) from solar storms and 

EMP attacks. Going forward, l expect that our collective attention to these issues and 

the risks posed by high-impact, low-frequency events will only increase. Later in my 

testimony I will explain some of the work we have done to date on these issues and 

how it helps to provide protection against potential EMP threats. 

EMP Threats 

I will now turn to EMP, as well as a related discussion about the threats posed 

by GMD. The bulk-power system may be impacted by electromagnetic events, such 

as naturally-occun·ing GMD or man-made EMP. In the case of EMPs, equipment is 

available that can generate localized high-energy bursts designed to disrupt, damage 

or destroy electronics such as those found in control systems on the electric grid. 

EMPs can be generated by devices that range from small, portable, easily concealed 

battery-powered units all the way through missiles equipped with nuclear warheads. 

As described, for example, in a recent report from the Los Alamos National 

Laboratory, depending on the yield of the device and the altitude of its detonation, 

EMP devices can generate three distinct effects of varying magnitude, each impacting 

different types of equipment: a short, high energy Radio Frequency-type burst called 

El that can destroy electronics; a slightly longer burst that is similar to lightning, 

termed E2; and a final effect, termed E3, that generates electric currents in power lines 

and equipment, which can then damage or destroy equipment such as transformers. 

In the case of GMDs, naturally occurring solar magnetic disturbances 

periodically disrupt the earth's magnetic field, which, in turn, can induce ctments on 

the electric grid that may simultaneously damage or destroy key transformers over a 

large geographic area. GMD events are similar in character and effect to the final 

phase of EMP, termed E3, as they can affect the same equipment including 

transformers. Any of these effects has the potential to cause voltage problems and 

instability on the electric grid, which could lead to wide-area blackouts. 

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10 

The risks posed by EMP and GMD events have been the subject of significant 

scientific research and debate, as well as broad discussion among regulators, elected 

officials, industry, and other stakeholders about the appropriate steps to address these 

threats. FERC has been actively involved in these discussions, and the threats posed 

to the grid by electromagnetic events, particularly GMD, have been a particular 

priority of mine during my time at FERC. While the threats posed by GMD and EMP 

overlap in part, our understanding of those threats and how to effectively mitigate 

them has led to difTerent approaches to address them. 

With these issues and challenges in mind, FERC has used both regulatory and 

more informal collaborative approaches to address EMP threats. 

FERC Regulatory Actions 

First, with respect to regulatory actions, FERC has acted through both its 

reliability authority under FPA section 215 and its ratemaking authority under FPA 

section 205 to support grid reliability efforts that help protect against EMP threats. 

Through its work on GMD, FERC has taken steps that help to mitigate one 

aspect ofEMPs, i.e., the effect of the E3 component on high-voltage transformers and 

other equipment. In 2013, FERC directed NERC to develop GMD reliability 

standards in a two-stage process. The first stage GMD reliability standard, which has 

been in effect since 2015, requires responsible entities to develop and implement 

operational procedures to mitigate the effects of GMDs. The second stage GMD 

reliability standard, which FERC approved in 2016, requires responsible entities to 

conduct initial and on-going assessments of the potential impact of a benchmark 

GMD event on bulk-power system equipment and the bulk-power system as a whole 

and to mitigate any assessed vulnerabilities. With respect to the second stage GMD 

reliability standard, FERC also directed NERC to develop modifications and perform 

additional GMD research on specific issues to ensure that the protections against 

GMD evolve with our improving understanding of the science. 

FERC has also taken other actions that provide a measure of protection against 

EMP threats, particularly through its efforts to protect the grid against physical 

threats. The nature of physical attacks - which, like EMP events, are intentional, 

manmade efforts to disrupt the electric grid - introduce additional complexities not 

present in events that have caused wide-spread blackouts and reliability failures in the 

past, such as vegetation-related events. Recognizing these risks, in 2014, FERC 

directed NERC to develop a reliability standard that addresses physical security 

threats. FERC approved NERC's proposed physical security reliability standard later 

that year. The physical security reliability standard requires responsible entities to 

3 
11 

mitigate assessed vulnerabilities to critical transmission facilities through resiliency 

or security measures designed collectively to deter, detect, delay, assess, 

communicate, and respond to potential physical threats and vulnerabilities. This 

standard, insofar as responsible entities harden their substations and improve 

perimeter security to address their assessed vulnerabilities, can help address the use 

of small, portable EMP devices that require close proximity to their intended targets. 

FERC, NERC, and industry have also dedicated significant attention to 

improving grid resilience. Resilience efforts cover a range of actions that grid owners 

and operators can take to reduce the risks associated with the loss of individual or 

multiple assets and to improve recovery and restoration following such losses. FERC 

has supported efforts to improve the design, planning, maintenance, and operation of 

the grid through its standards and rate work, as well as through collaborative efforts. 

For example, some of these efforts stem from requirements in mandatory reliability 

standards to ensure backup capabilities for the loss of critical assets, or to de-risk 

critical assets, which reduces the potential for cascading outages. 

One important element of grid resilience is ensuring adequate inventories of 

critical grid infrastructure, particularly long-lead time construction items like highvoltage transformers. Through its rate-making authority, FERC has issued orders to 

provide clarity on how it will address services provided by Grid Assurance, a 

company created by several electric utilities and energy companies, and Edison 

Electric Institute's (EEl) STEP program. Over the last two years, FERC issued orders 

addressing important cost recovery and rate design questions concerning Grid 

Assurance's service model, which is intended to supp011 transmission owners in the 

procurement, maintenance, and delivery of transformers and related equipment in the 

event of a loss of a critical transformer. Similarly, EEl's STEP program, which FERC 

approved in 2006, provides a sharing service for backup or spare transfonners among 

participating transmission owners. These programs are intended to enhance grid 

resilience and protect customers from prolonged outages by providing electric utilities 

with timely access to emergency spare transmission equipment that otherwise can 

take months or longer to acquire. 

As noted above, the GMD and physical security standards help provide 

protection against particular aspects of the EMP threat. However, FERC has not 

directed NERC to develop a standard specifically targeting EMP. To be clear, I 

believe this is the result of reasoned consideration of the issue. FERC has repeatedly 

demonstrated a willingness to direct NERC to develop or modify a reliability standard 

where FERC identifies a gap in the protection of the bulk-power system; indeed, the 

physical security and GMD standards, as well as an ongoing effort to develop a 

standard to address supply chain threats, were the result oCFERC directives. It is also 

worth noting that directives to develop new standards have been supported by FERC 

commissioners from both parties, demonstrating a strong bipartisan commitment to 

4 
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grid reliability. 

I recognize that some parties have challenged FERC' s decision to proceed with 

a GMD standard that did not also include EMP threats more generally. I believe that 

FERC's approach has been prudent, given our understanding of those threats and 

potential mitigation to address them. With GMD, FERC was able to identify and 

direct a structured plan of monitoring, assessment, and mitigation that targets specific 

critical grid components (e.g., high voltage transfonners) for protection against a 

GMD event. That plan was the result of years of FERC, NERC, and industry efforts 

to understand the GMD threat and determine how best to protect against it. 

By comparison, large-scale EMP attacks pose a very different threat to the grid, 

and one that, to date, FERC has not determined is well-suited to a mandatory 

reliability standard at this time. Although much work has been done, there remains a 

significant amount of scientific research and debate underway about EMP threats. For 

example, in January 2017, DOE, in its role as the Sector-Specific Agency for the 

Energy Sector, issued its Electromagnetic Pulse Resilience Action Plan, which lays 

out a multi-year effort to improve our understanding of EMP threats, effects, and 

impacts; identify priority infrastructure; test and promote mitigation and protection 

approaches; enhance response and recovery capabilities; and share best practices. 

DOE, through the Los Alamos National Laboratory, is working with the Department 

of Homeland Security (DHS) to advance our understanding ofEMP's effects on the 

electric power system. DOE's Idaho National Laboratory is also working to develop 

potential EMP strategies, protections, and mitigation for the electric grid. Similarly, 

the Electric Power Research Institute is currently conducting a multi-stage study of 

grid impacts associated with EMP threats, including evaluations of the impacts ofE1, E-2, and E-3 components. 

In addition, last year, Congress directed DHS to conduct research and 

development on how to mitigate the consequences of threats ofEMP and GMD, and 

report periodically over several years. A year earlier, Congress also re-authorized the 

EMP Commission, initially created in 2001, to continue to assess and report on the 

threats posed by EMP. 

EMP threats present unique challenges as well. Unlike naturally-occuning 

GMD, which can be measured and subject to rigorous public scientific debate, EMP 

threats stem from hostile actors, particularly foreign nations, which introduces 

complexities regarding confidential national security information that are not readily 

adapted to FERC proceedings or the NERC standards development process. Any 

standard we may adopt in the future may need to differ from our usual standards, in 

order to avoid the security risk of announcing publicly the limits of our protective 

mitigation. 

5 
13 

Furthermore, while there has been much written regarding the nature of the 

threat from EMP, consensus has not been reached regarding how best to protect 

against it. While the military has developed protocols to protect key assets, these 

protocols have been described by Los Alamos National Laboratory as "not widely 

implemented in civilian applications due to the expense," and by Idaho National 

Laboratory as "focused on load center protection for communication stations, control 

and mission critical facilities, not distribution, transmission and large generation 

assets for the electric power grid." Given the scope and potential cost of an effort to 

protect the entire grid against an EMP attack, I think it is prudent that FERC not 

launch a mandatory standard unless it concludes that the standard would effectively 

mitigate the threat at a justifiable cost. Ongoing research by DHS, DOE, and others 

eventually may support such a conclusion, but to date, FERC has not reached that 

conclusion. 

That said, as described below, FERC remains actively engaged in efforts to 

understand and address the EMP threat. Those efforts will continue, and I am 

confident that, should FERC ultimately determine that a reliability standard is 

warranted, it will exercise its authority under FP A section 215 to require one. 

Collaborative Efforts 

FERC is also actively involved in efforts beyond its standards process. As 

noted above, FERC works closely with Federal agencies, state partners, and industry 

to identify key energy facilities; provide threat briefings, including on GMD and EMP 

threats; assist with the development and identification of best practices for mitigation; 

and cooperate with international pminers to convey threat and mitigation information, 

as well as encourage adoption of best practices for mitigation. DOE, DHS, and the 

Department of Defense (DOD) have been particularly active on EMP issues, with 

DOE engaging the national labs to help support its efforts. In this regard, in 2015 I 

had the opportunity to visit the Idaho National Laboratory for a couple of days to learn 

about its work on cybersecurity and GMD issues. 

Many of FERC's collaborative actions involve cross-sector, interagency, and 

public-private efforts to improve our collective understanding of GMD and EMP 

threats. For example, FERC participates in DOE's Electric Sector Coordinating 

Council, which is evaluating both EMP and GMD threats. In 2010 FERC, DHS, and 

DOE released a report conducted by the Oak Ridge National Laboratory that 

investigated and identified the effects of, and mitigation measures for, both GMD and 

EMP on the Nation's power grid. FERC is an active participant with the Energy 

Infrastructure Security Council, assisting with national and international 

collaboration. These efforts include the publication of resources in collaboration with 

DOE and participation in state and national table-top exercises simulating EMP 

attacks and coordinated responses as well as potential proactive protection measures. 

6 
14 

FERC continues to monitor international efforts to address EMP and GMD, including 

collaborating on both foundational and best practices. In 2016, FERC exchanged 

information with Norway and expects to do so with both the UK and Israel later this 

year. On a national level, FERC briefed the EMP Commission earlier this year and 

has offered further collaboration to DHS, DOE, DOD, the national laboratories, and 

industry. 

In addition, in November 2014, the National Science and Technology Council 

created the Space Weather Operations, Research, and Mitigation (SWORM) Task 

Force to develop high-level strategic goals for enhancing national preparedness for a 

severe space weather event. The SWORM Task Force is co-chaired by members from 

the Office of Science and Technology Policy, DHS, and the National Oceanic and 

Atmospheric Administration. FERC has participated in the SWORM Task Force's 

efforts from its inception. As a result of this work, FERC was an active participant 

with the development and release of both the National Space Weather Strategy and 

the National Space Weather Action Plan. FERC also assisted with the follow-up 

Executive Order released in October 2016 that, among other things, directed DOE 

and DHS to "develop a plan to test and evaluate available devices that mitigate the 

effects of geomagnetic disturbances on the electrical power grid through the 

development of a pilot program that deploys such devices." FERC has offered further 

assistance to DOE should this work proceed. 

Most recently, FERC has assisted both DOE and DOD to identify defenserelated critical electric infrastructure as directed under the FAST Act, thereby 

assisting with their decisions regarding EMP and GMD protection at these facilities. 

Further, in response to a directive of the FAST Act, DOE, after consulting with FERC 

and others, submitted a Strategic Transformer Reserve report to Congress in March 

2017. This report described the impo1iance of maintaining a strategic transformer 

reserve, as well as the cuiTent efforts underway by the industry and government to 

mitigate potential threats to the U.S. bulk-power system created by the vulnerabilities 

of these transformers. Specific to the subject oftoday's hearing, these threats include 

both EMP and GMD events. DOE recommends encouraging and supporting an 

industry strategic transformer reserve driven by voluntary industry actions and 

NERC's physical security reliability standard's requirements. DOE also recommends 

that it re-assess this approach in the future with FERC and electricity industry partners 

to determine whether sufficient progress has been made through this approach or if 

alternative actions by the government might be necessary. As noted above, FERC 

has encouraged these efforts through its collaborative outreach and ratemaking 

authority. 

Thank you again for the opportunity to testify today. I would be happy to 

answer any questions you may have. 

7 
15 

The CHAIRMAN. Thank you, Chairman LaFleur. 

Speaker Gingrich, welcome. 

STATEMENT OF HON. NEWT GINGRICH, CHAIRMAN OF THE 

BOARD, GINGRICH PRODUCTIONS 

Mr. GINGRICH. Thank you very much for holding this hearing. I 

think it’s very important and I commend the Chair and the members for putting time in on this. 

I just want to focus backward from consequence. 

A good friend of mine and co-author of several novels, Bill 

Forstchen, wrote a novel called, ‘‘One Second After,’’ which is the 

study of a small town in North Carolina during the year after electricity was knocked out by an EMP attack. And it’s really worth 

looking at because we take electricity for granted. Even in relatively short outages as we had in April in New York, San Francisco and Los Angeles, people are remarkably inconvenienced. 

But it turns out, for example, all the drugs we rely on for a wide 

range of things require refrigeration. And the minute you start 

knocking out the system, there’s a cascade of consequences. 

We’ve known indirectly since 1859 with the Carrington event 

that something can happen that has an effect back then and 

knocked out telegraph lines but we weren’t relying on everything 

that’s electronic that we do today. 

We’ve known since 1962 that there can be a manmade event at 

a high altitude which knocks out electricity because it knocked 

from Johnston Island, it knocked out lights in Honolulu. 

The challenge we have with the electric grid is it’s actually designed for efficiency and it’s a remarkable achievement. The problem is efficiency, it leads to fragility. And so, from your perspective, 

you both have to look at notable points which could be knocked out 

physically or by a local EMP. You have to then look at 

cyberattacks, and then you have to look at EMP attacks. 

The grid is vulnerable at all three layers. And if somebody were 

to methodically come in here, they would find, I think, there are 

as few as nine notable points you could knock out that would have 

a catastrophic effect because it would lead to a cascade of systems 

to shutting down. 

If you then looked at the effect, potentially, of either the series 

of local EMP attacks or a high-altitude EMP attack, you’re talking 

about a catastrophic event from which, conceivably, you couldn’t recover for years. 

So, I would—a couple of quick things. One, the Congress should 

look at EMP attacks as one of the three great threats to our survival. The other two being cyber warfare and nuclear weapons, and 

they should regard all three as catastrophic. For us to survive as 

a civilization we have to be able to defeat all three of those threats. 

Two, I think that the Congress should communicate a sense of urgency. There are a lot of people doing a lot of good things at a relatively leisurely pace and trying to be reasonable. If you work back 

from consequence, you rapidly become unreasonable because the 

consequences are so horrible. This is like 9/11 where we said, gee, 

we hadn’t thought about an airplane hitting a building which is 

nonsense. Tom Clancy had written about it a decade earlier, but 

nobody wanted to cut through and say so, what would you have to 
16 

do to stop that from happening? After the event, we did all sorts 

of things to make it harder to take over an airplane. We’re in the 

same boat right now except here we’re gambling on our civilization. 

This is vastly bigger than 9/11. 

I would suggest a couple things. One, that Homeland Security 

and Department of Energy should have some very rigorous war 

games thinking through all the permutations of what could happen 

and they should look for the key notable points where you could, 

in fact, begin to fix the system because there are a number of steps 

that are going to be taken to make the system more resilient and 

to make it more difficult to take out. Two, I would look at the new 

infrastructure bill to consider having a substantial part of the national security infrastructure component. Three, if you were to go 

through and cut out a lot of the red tape that the electric industry 

has to deal with, the time value of money you would save would 

probably more than pay for everything you’re going to ask them to 

do on EMP. 

And so, there are very practical things that can be done here but 

you need to somehow communicate to the Executive Branch, you 

need a sense of urgency. We need to understand that every morning we get up, we’re a step away from catastrophe. 

And let me just note that the NASA has estimated that the potential for the sun to hit us with a, it’s different than a man-made, 

but nonetheless equally dangerous, the potential for the sun to hit 

us with the, effective of the Carrington effect is about 12 percent 

per decade. That we’re now overdue for that happening. We apparently came within one week of it happening and happened to be 

out of position for the sun so the solar flare missed us. But that 

should give us a reminder. 

I’ll just close by saying there’s a historium. Work back from the 

consequences. When you have a high likelihood that over the next 

20 to 30 years something this consequential is going to happen, 

there has to be a sense of urgency by blocking it from occurring because if it does occur, it could literally end civilization as we know 

it. 

[The prepared statement of Mr. Gingrich follows:] 
17 

Hearing to examine the threat posed by electromagnetic pulse and policy options 

to protect energy infrastructure and to improve capabilities for adequate system 

restoration 

10 a.m., May 4, 2017 

Dirksen Senate Office Building 

Room 366 

Speaker Gingrich: 

Good morning, I'd like to thank Chairman Murkowski, Ranking Member Cantwell, and the committee 

members for inviting me to testify today about the very real danger that electromagnetic pulse poses to 

the United States. 

I wrote about this danger in my book To Save America in 2011. 

Then, I acknowledged that we have known about the threat of electromagnetic pulse (EMP) since the 

mid-twentieth century. We learned then that setting off a nuclear explosion in the right way, and at the 

right altitude could simulate an enormous lightning strike, which could damage electronic devices and 

render them inoperable. Writing that book, I learned that testing hydrogen bombs in the Pacific resulted in 

burning out lights in Honolulu, which was 1,200 miles away from the test site. 

As I wrote in 2011, anyone who has ever had a household appliance ruined by a power surge can 

understand the danger of EMPs, but our military has not fully assessed how an EMP strike could impact 

people in cities across the United States- and especially along the East Coast. 

In 2004, Congressman Roscoe Bartlett called together a panel of nuclear physicists to study this issue. 

And according to their report. one EMP weapon detonated over Omaha would cripple half the economy. 

Further, they found that Russia, China and North Korea were working to develop EMP weapons- and the 

United States was quite vulnerable to an EMP attack. 

Bill Forstchen, a friend who has co-authored books with me, wrote a sobering and horrifying novel about 

an EMP attack on the United States. The book is called One Second After, and in it Forstchen described 

how a small North Carolina town would be affected over the course of a year after a successful EMP 

attack. The story really illustrates how terrible such an assault could be. 

As I argued in To Save America, within the next decade, there is no question that the United State should 

take action to develop a hardened, more resilient electrical system that could better withstand an EMP 

attack. Frankly, it is a matter of national survival. 

The Commission to Assess the Threat to the United States from Electromagnetic Pulse (EMP) Attack 

reported in 2008 that, "the electromagnetic pulse generated by a high altitude nuclear explosion is one of 

a small number of threats that can hold our society at risk of catastrophic consequences." 

The report went on to say: "Because of the ubiquitous dependence of U.S. society on the electrical power 

system, its vulnerability to an EMP attack, coupled with the EMP's particular damage mechanisms, 

creates the possibility of long-term, catastrophic consequences. The implicit invitation to take advantage 

of this vulnerability, when coupled with increasing proliferation of nuclear weapons and their delivery 

systems, is a serious concern. A single EMP attack may seriously degrade or shut down a large part of 

the electric power grid in the geographic area of EMP exposure effectively instantaneously. There is also 

a possibility of functional collapse of grids beyond the exposed area, as electrical effects propagate from 

one region to another." 

Just consider if one of these pulses were to be unleashed and disabled the power infrastructure on the 

East Coast. This is not simply about the lights going out. Consider the consequences of hospitals and 
18 

public safety agencies being without power, communication, or transportation for a significant amount of 

time. 

This is a topic I am incredibly concerned- and passionate- about. I look forward to speaking with you 

about it today. 
19 

The CHAIRMAN. Speaker, thank you very much for your comments and reminding us of the imperative here. 

Ambassador Cooper, welcome. 

STATEMENT OF AMBASSADOR HENRY F. COOPER, FORMER 

DIRECTOR, STRATEGIC DEFENSE INITIATIVE ORGANIZATION 

Ambassador COOPER. Madam Chairman, Ranking Member and 

members, I very much appreciate the opportunity to testify before 

you today on my views of this important issue. 

Actually, Speaker Gingrich has covered a lot of my material 

which is a good thing because I wasn’t sure I could get through 

even my abbreviated comments here. 

I guess I would like to say that I add that we’re living through 

the most dangerous period of my lifetime for a number of reasons, 

but the vulnerability of our national electric power grid is among 

the most important and we are collectively continuing to endure or 

to take ineffective countermeasures to deal with it. 

Frankly, I’ve become so concerned about the dysfunctionality of 

the Federal Government, both the Executive and the Legislative 

branches, that I am now spending most of my time working with 

private citizens, local and state authorities and happily, some key 

people in the electric power industry to begin working this problem 

from the bottom up believing that if enough of our citizens gain a 

real understanding of the issues and how they can actually turn— 

must be addressed at the local level then Washington eventually 

will begin to do the right thing in addressing this urgent problem. 

I went through another set of issues in my summary comments 

here that have largely been covered already that I want to skip 

over and turn to the comments written by the Chairman of the 

EMP Commission which was chartered, as you know, by the Congress to deal with these issues, in a letter April 20th, to Secretary 

of Energy Perry. The EMP Commission, and these are their comments, I want to make clear. I share their views for a lot of reasons, but these are their comments. They view the current efforts 

to address natural EMP threat are ‘‘producing grossly inadequate 

standards for protecting the grid,’’ to quote its Chairman, Bill Graham, who is a colleague of mine for many years. He further noted 

the Commission’s concern over misleading and erroneous studies by 

NERC and others that grossly underestimate the natural EMP 

threat from solar storms and dangerously have become the basis 

for grossly inadequate standards approved by FERC. 

Perhaps more importantly he noted the Commission’s concern 

that the 2014 Obama Administration Intelligence Community Assessment of the nuclear EMP threat is profoundly erroneous and 

perhaps the worst ever produced on EMP, and that has been used 

to thwart efforts to protect the nation against nuclear EMP by dismissing the threat, despite overwhelming evidence to the contrary. 

He also noted that the nuclear EMP is the ultimate cyber weapon threat and its military—in the military plans of Russia, China, 

North Korea and Iran for combined arms cyber warfare that they 

will see decisive new revolution in military affairs as a consequence. 

He indicated to Secretary Perez and Perry that the Commission 

is also very concerned over misleading and erroneous studies re-
20 

cently completed by industries, Electric Power Research Institute 

and grossly underestimate the nuclear EMP threat. 

These and other bureaucratic issues led me, a couple of years 

ago, to lose confidence that we were ever going to deal with this 

problem from the top down, and I decided to try to work it from 

the bottom up. 

My written testimony goes into some detail discussing the work 

I am doing, along with Duke Energy engineers. Duke Energy, as 

you probably know, is among the largest, if not the largest, energy 

company in the nation. And we were working on a pilot study in 

York County and Gaston in South Carolina and Gaston County in 

North Carolina. And of course, Duke’s corporate headquarters are 

in Mecklenburg County which is a neighbor to those two counties. 

We are engaging with local authorities, particularly the folks in 

Rock Hill which is a bedroom community for Charlotte as well as 

an important area of its own. 

This is important because the nature of the grid is, I’m sure this 

Committee knows, a crazy quilt patchwork of co-ops and electric 

utility companies across the nation, some, I don’t know, 2,000 or 

3,000, I understand. Unless those folks are actively involved in 

working the problem and providing the loading conditions that they 

can and will need at Duke Energy to produce the power and get 

it to the local subscribers, then we’re going to have the consequence 

that the Speaker referred to earlier. 

Water and waste water is a key matter, for example. Duke Energy doesn’t provide the electricity to the water and waste water 

operations in Rock Hill. That’s provided by a different utility. And 

unless that utility is working hand-in-hand with Duke, then you’re 

going to have hospitals running out of electricity very shortly and, 

as I understand it, without water those hospitals will be experiencing deaths within hours. 

So this is an important issue. I urge you to have the EMP Commission which, in my view, is the nation’s top authorities. Many of 

the engineers were involved in the DoD from the earliest of days 

dealing with this issue, and that is where the expertise originally 

has been. The DoD is not particularly helpful in working this problem today. 

The Department of Energy, while I have great respect for the engineers at our laboratories, is reinventing lessons that were learned 

the better part of a half century ago. And it’s absurd, in my judgment, that we find ourselves in this situation. 

I hope the Committee can help deal with the communication 

problems within the Executive Branch as well as help us work this 

problem from the bottom up. 

Thank you, Madam Chairman. 

[The prepared statement of Ambassador Cooper follows:] 
21 

ON PROTECTING THE ELECTRIC POWER GRID 

Testimony of Ambassador Henry F. Cooper 

To 

The U.S. Senate Committee on Energy and Natural Resources: 

May 4, 2017 Hearing to examine the threat posed by electromagnetic pulse (EMP) and policy 

options to protect energy infrastructure and to improve capabilities for adequate system restoration. 

Madam Chairman, thank you for this opportunity to share my views on the need to address the 

fragilities of the electric power grid and the means to do so. ! view that the related current status 

and plans known to me leave the grid vulnerable to existential threats. And l believe we have the 

technical means to rectify these vulnerabilities-but are regrettably blocked from doing so, 

primarily because of political conditions that this Committee can, and hopefully will, address 1

• 

l consider that we are living in the most dangerous period of my lifetime for a number of reasons, 

but the vulnerability of our national electric power grid is among the most important ones. 

Moreover, I believe we have had clear warning of the nature of this threat for years. and are 

collectively continuing to ignore and/or take ineffective countermeasures to deal with it. Frankly, I 

have become so concerned about the dysfunctionality of the federal government in dealing with the 

threat that I am now spending whatever remaining time the Good Lord gives me to work with local 

and state authorities and private citizens to address the key issues from the "bottom up"-and I will 

address one of these important initiatives. If enough of our citizens gain an understanding of the 

issues and how they can-actually must--be addressed at the local level. then I believe Washington 

will eventually do its part in addressing this urgent problem. 

The following sections briefly review some important lessons from recent events and their 

implications for understanding the various threats to the electric grid, including from natural and 

manmade EMP; the nature of this so far poorly addressed existential EMP threat; the maturing 

related threat posed by hostile adversaries and our thus far inept response; and recommended 

initiatives to counter that threat and protect the grid. 

IMPORTANT LESSONS FROM RECENT EVENTS 

To set the stage for discussing EMP issues. please consider the fragility/vulnerability of the electric 

grid illustrated by the events of Friday just three weeks ago (April 21 51) when nearly concurrent grid 

outages occurred in New York City. in Los Angeles and particularly in San Francisco where, for 

hours. there was consequent jammed traffic, people stranded in elevators, hospitals on backup 

generators and other disruptions that continued for several hours before emergency management 

operations restored electric power2• 

1 Please permit me to tell you I believe you should consider my views on this important~-and I believe-urgent 

matter. Jam a PhD engineer. very pertinent experience-from working on developing military and civilian 

systems at Bell Telephone Laboratories in the early 1960s, to over 20 years conducting research and developing 

simulators to test our strategic systems against nuclear weapons effects. to overseeing the Research. Development and 

Acquisition of U.S. Air Force Strategic and Space Systems under Presidents Carter and Reagan, to oacKsvcmo•m" 

bilateral negotiations with the Soviet Union while developing our national space arms control policy and 

Chief U.S. Defense and Space Negotiator with the Soviet Union under President Reagan. as Strategic Defense 

{SDI) Director and Acquisition Executive for atl our missile defense programs under President George ltW. Bush, and 

for 15 years as Chairman of the Board of Directors of a successful R&D company. In short, I've been around and 

solving technical and political problems or concern for entire professional career. 2 See a Reuters review of these events 
22 

Joseph Weiss, an international authority on cybersecurity, control systems and system security 

regularly gives his views at http://www.controlglobaLcom/blogs/untcttcred/. On April24, he noted 

San Francisco's 7-hour outage was due to cascading effects triggered by a single breaker in one 

allegedly low-impact substation, the Larkin Street Substation. Weiss noted problems at this Larkin 

substation were identitied years ago, but authorities have not taken remedial action. On April 28, he 

noted some root causes, I ike "thermally overloaded transmission lines" were well known years in 

advance and that this "home town" event should raise red tlags at the Department of Energy (DOE), 

the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability 

Corporation (NERC) and the need for substantial improvcments 1

. 

Indeed! This regulatory system is failing to protect the nation's electric grid from many threats, 

including EMP. 

IMPORTANT JMPLICATJONS FOR THREATS TO THE GRID 

From my perspective, Weiss' most important observation is that the major San Francisco grid 

failures cascaded from a single relatively "minor" event: i\ lowly breaker failure in a single 

substation, however caused4• This observation brings to mind conclusions by former FERC 

Chairman Jon Wellinghofffollowing the April 16,2013 San Jose's Metcalf Substation attack that 

similar cascading failures from only nine identifiable substations could bring down the entire 

electric grid for an extended period 5 But the Larkin Substation was enclosed in a structure that 

would have shown evidence of Metcalf kind of terrorist attack with rifle fire-not evidenced in San 

Francisco three weeks ago. Maybe terrorists with radio-fi·equcncy (RF) weapons could have 

triggered such a failure, but as Weiss pointedly wrote: "Given the walled enclosure, a physical 

attack such as the rifle attack against the PG&E Metcalf substation would not be possible." 

Moreover, while simultaneous terrorist and cybcrattacks could have been planned to occur across 

the nation", the concurrent events in cities on both the East and West Coasts more likely reflect the 

April 21 (updated on April 22) warning by The Sun (a United Kingdom News Company) that "a 

mega hole in the Sun could cause blackout mayhem" due to its "belching" of radioactive particles 

toward the Earth 7

• Thus, such "space weather" effects are understood and were anticipated. 

NATURAL AND MANMADE EMP 

Such ''Solar Hole" events arc longer lasting but much less damaging than would be a Coronal Mass 

Ejection (CME) like in the 1859 Carrington event that interacted with the earth's geomagnetic field 

2 
23 

to produce a Geomagnetic Disturbance (GMD) that destroyed telegraph lines, with little impact on 

that low-tech agrarian society. Today, a Carrington-class CME/GMD would cause catastrophic 

damage to critical electronic infrastructure, particularly our unprotected electric power grid. We 

missed such an event by a week in 20 I2, as explained by NASA and other scientists 8 who study 

"Space Weather," or •'natural" EMP. They project a I2-percent-per-decade likelihood for a 

Carrington CME/GMD. 

While current efforts (however meritorious-see he low) seek to protect the grid against such natural 

EMP events, little to nothing is being done to protect the grid against much more stressful 

''manmade" EMP, caused by nuclear weapons detonated high in or above the Earth's atmosphere. 

Notably, if the grid is protected from manmade EMP attack, it will be protected from Natural EMP 

events-but the converse is not true, because of fundamental differences in the EMP pulses. 

Missing in the Natural EMP pulse arc the high frequency components that threaten solid state 

electronics, like the supervisory control and data acquisition (SCAD A) systems that control much of 

our critical intl'astructure, including our electric grids and natural gas and petroleum pipelines. 

OUR ENEMIES PLAN EMP A TTACKS-~A RAPIDLY MATURING THREAT 

Such manmade EMP attacks are known to be included in the doctrine and planning of Russia, 

China, North Korea and Iran. One particularly important report on Iranian doctrine and strategy was 

referenced by Rep. Trent Franks at the July 21, 2015 International Electric Infrastructure Security 

(EIS) Summit in Washington, DC9 He stated that the conclusion of this doctrine is that nuclear 

EMP is "an advanced and useful weapon in modern warfare." 

These nations also have information on how to build low-yield "Super" EMP weapons. (It is a myth 

that high yield nuclear weapons are required to produce extensive and intensive EMP effects.) In 

2004, the EMP Commission was advised by very senior Russian Generals, experts on nuclear EMP 

weapons, that this "Super'' EMP knowledge had been transferred to North Korea, which would 

probably develop these weapons in a few years w We should also assume that Iran knows whatever 

North Korea knows and has whatever the Mullahs wish to buy. 

Thus, North Korea and Iran may now or in the foreseeable future actually have such low yield super 

EMP weapons-indeed, that possibility could explain North Korea's underground low-yield nuclear 

tests-and we should assume Iran also has that information. David Albright, an often quoted expert 

on these matters, estimates that North Korea already has I 3-30 nuclear weapons and is capable of 

building 3-5 each year 1

I 

Both nations could deliver an EMP attack on the United States by simply detonating a nuclear 

weapon carried by one of their satellites as it passes over the United States-no hardened reentry 

vehicle or accurate guidance system is needed as would be the case for a conventional 

intercontinental ballistic missile (ICBM) targeted on a city or other surface target. Both nations 

s See for a detailed discussion. 9 Rep. military doctrine called Passive 

Defense from \vhich emphasizes the importance of targeting critical inf!·astructure in warfare and references 22 

times the use ofEMP as a weapon to damage or disable the civilian electric grids of potential opponents. The Iranian 

doctrine states that nuclear and non~nuclcar E:vtP weapons operate differently. but morally are the same. 

w Personal Communication with Dr. \.Yilliam R. Graham, EMP Commission Chairman. 11 See David Albright, ·'North Korea's Nuclear 

Security, Apri128, 2017 
24 

have launched such satellites-Iran successfully placed satellites in orbit in2009, 2011,2012 and 

2015 but had a failure in 2016 and plans more attempts 12 ; and North Korea, after several failed 

attempts, in 2012 and 2016 13 . 

These satellites were launched over the South Polar regions to approach the United States, from our 

mostly undefended South. The test launches generally are reported to be of concern because they 

could be a stepping stone to developing ICBMs-as is certainly the case. However, they also could 

be intended to develop a means to carry out an EMP attack on their first passage from the South 

over the United States 14 • And that is why that possibility should not continue to be ignored, 

especially since we have little if any defense against that possibility". 

Moreover, the 2008 EMP Commission report 16 noted that Iran had in the late 1990s launched a 

ballistic missile from a barge in the Caspian Sea, and sent electronic signals that suggested it 

''triggered" a simulated a nuclear weapon detonation at altitudes up to 400 kilometers, to produce a 

potentially devastating EMP. To date, the United States has not deployed a ballistic missile defense 

(BMD) system to counter this identified threat that could originate on a vessel off our coastsincluding from the Gulf of Mexico. We are essentially defenseless against this plausible threat 17• 

MISSILE DEFENSE ROLE 

Our Aegis BMD ships have demonstrated an ability to shoot down such threat missile/satellite 

attacks-if they operate with appropriately trained crews in response to the identified threat, 

especially when they are near our coasts. 

Aegis BMD ships do not operate in the Gulf of Mexico, but the Aegis Ashore BMD system, now 

operational in Romania and slated to be operational in Poland by the end of this year, could be 

deployed on our military bases around the Gulf to protect us from such an attack 18 • 

orbit but was subsequently 1

'

1 In february 2016, I joined James Woolsey, Reagan Science Advisor (and EMP 

Commission Chairman) Dr. William R, Graham, Former Chairman of the National intelligence Council Fritz Ermarth 

and EMP Commission Staff Director Or. Peter Vincent to underestimates of North Korea's and Iran's 

;;;'m~~02~~::\'~~~~~D;f;;:~:o/;~L?,ll~=;~'!:i:~ft~~~~~~~~~,~~~~~~·take the North 

in all directions.'' Furthermore, Secretary of State Rex 

with Bret Bair last Thursday. It would be reassuring 

if U.S. authorities also recognized that such missiles headed south can also deliver a devastating EMP strike by carrying 

a nuclear weapon payload and detonating it over us in its first orbit, rather than reentering the atmosphere to attack a 

American city. North Korea could plausibly accomplish this potentially existential threat attack today. 16 The 2004 and 2008 reports of the Congressional Commission to Assess the Threat to the United States ti·om 

Electromagnetic Pulse Attack. or the EMP Commission, can be found its webpage at htt.llii~DO:&lll!lfllill!Dli!ili.!cQJLQJ]~. 

17 Note that in 2013, a North Korean vessel was caught from Cuba two 

capable rockets (without \:Varhcads) under tons of sugar. 

as Director, is in my opinion our most costnow deployed on 35 ships around the world and soon to be at 

several sites in a based mode, including in Hawaii, It should be built on military bases around the Gulf of Mexico, 

beginning on Tyndall AFB in Panama City~ Florida-home of lst Air Force which has the lead mission for air defense 

of the continental United States, the Dominican Republic and Puerto Rico. No additional R&D is needed to protect 

Americans at home, just build the same Aegis Ashore system now deployed to protect our allies and overseas troops. 

4 
25 

Congress and the President also should give our Aegis BMD ships a homeland defense mission 

when they are near or in our coastal waters-including while in port, e.g., at Norfolk, Virginia 19 • 

These BMD capabilities are technically available in the near term. I also urge that we return to the 

development of the most cost-effective BMD systems of the Strategic Defense Initiative (SDI) era 

(March 1983-January 1993)-those based in space that can intercept threat ballistic missiles 

beginning in their boost phase, while their rockets are still burning. We referred to this most costeffective BMD concept as "Brilliant Pebbles." That program was cancelled abruptly in 1993 by the 

Clinton administration and as yet has not been revived. With the needed funding and management 

skills, 1 believe such a cost-effective system could be deployed within five or so years, now even 

more capable and for less money because of more advanced technology developed since 199320• 

HARDEN THE GRID 

But no defense is perfect-so we should "harden" our critical civil infrastructure, especially the 

electric power grid, against the full complement of threats. And it should be understood that if any 

adversary mounts an EMP attack against us, he will employ a preemptive combination of cyber, 

physical, radiotl·equency and other weapon attacks to confuse and devalue our response. 

As already acknowledged by the Obama administration, the grid must be hardened to protect 

against a GMD event that will surely one day occur, only its timing is uncertain. But as noted 

above, even if this hardening effort is successful (currently an unlikely prospect, based on my 

understanding of progress toward that end), it will not protect the grid from the manmade nuclear 

EMP threat-or from other threats that might be posed by terrorists or rogue regimes. Rather, we 

should be addressing the manmade nuclear EMP threat, together with protection against natural 

geomagnetic disturbances, with competently executed, integrated efforts that work the problem 

from the bottom up--beginning at the local level. Such efforts should also include protection 

against physical, cyber and radio frequency weapon attacks. 

As a prelude to my recommendations on how best to deal with this threat-which focus on 

protecting the grid from the bottom-up (beginning at the local level in conjunction with cooperative 

electric power companies (CoOps)). consider the Chairman of the EMP Commission Dr. William 

R. Graham's observations in his April 20 letter to Secretary of Energy Rick Perry21 : 

19 A few years ago, there were usually 4-6 Aegis ships near our East Coast or in port there. If coupled vvith one of our 

relatively inexpensive TPY M2 radars appropriately placed in New England, they could supplement our Ground Based 

Interceptors in Alaska--especially against lCBMs fl·om fran, long before an additional East Coast site can be built. 

Se-c [lttp://wv,m-.nmiunalrcvicw.com/artic!c/442532/ for a ,Vationaf Review article, •·Hovv· Trump can Fultill Reagan's 

Defense Vision'' explaining the basis for a cost-effective "rapid startup'' strategy, co-authored \vith Retired US Army Lt 

General Mal O"Ncill, my Deputy SDJ Director (and subsequently the BMD Acquisition Executive of the Clinton 

administration and Assistant Army Secretary flw Acquisition, Logistics and Technology); Dr. Robert L. Pfaltzgraff Jr. 

president of the Institute flx Foreign Policy Analysis (IFPA). Inc .. and Shelby Cullom Davis Professor oflnternational 

Security Studies at The Fletcher School, Tul\s University, and chairman of the Independent Working Group on Missile 

Defense. and Retired USAF Colonel Rhip Worrell who was the SDI Brilliant Pebbles Program Manager. 21 !n introducing the tO!lmving list, Dr. Graham indicated the context for these observations was to explore with the 

Secretary of Energy how the Department V.'as going to support to the Critical Infrastructure Protection Act (FY 

2017 National Defense Act. Section 1913, '"EMP and GMD Planning. Research and Development, and 

Protection and Preparedness"' p. 1762), which directed the Department of Homeland Security: to develop plans to 

protect the electric grid and other critical infi·astructures from EMP; to educate and train federal, state and local 

emergency p!anners and first responders on the l:Jv1P threat; and to conduct research and development to mitigate EMP. 

5 
26 

1. Nuclear EMP is the ultimate cyber weapon in the military doctrines and plans of Russia, China, 

North Korea and Iran for Combined Arms Cyber Warfare that they see as a decisive new 

Revolution in Military Affairs. 

2. Protecting the grid from the worst threat-nuclear EMP attack-can also mitigate lesser 

threats, including from natural EMP from solar storms, non-nuclear EMP from radiofrequency 

weapons, cyber-attacks, physical sabotage and severe weather. 

3. State electric grids can be "islanded" by installation of surge arrestors, blocking devices, 

Faraday cages, and other devices to protect individual states, even though they may be part of a 

larger regional electric grid, from a prolonged catastrophic blackout. For example, Texas State 

Senator Bob Hall has introduced legislation to harden the Texas Electric Grid. 

4. The Commission is profoundly concerned that the 2014 Obama administration intelligence 

community assessment of nuclear EMP is profoundly erroneous, and perhaps the worst ever 

produced on EMP, and that has been used to thwart efforts to protect the nation against nuclear 

EMP by dismissing the threat, despite overwhelming evidence to the contrary. 

5. The Commission is very concerned over misleading and erroneous studies by the NERC and 

others that grossly underestimate the natural EMP threat from solar storms, and dangerously, 

have become the basis for grossly inadequate standards for EMP/GMD protection approved by 

the Obama administrations' FERC. 

6. The Commission is also concerned over misleading and erroneous studies recently completed 

by industry's Electric Power Research Institute (EPRI). in cooperation with Obama 

administration holdovers in the Department of Energy, that grossly underestimate the nuclear 

EMP threat. 

Dr. Graham's observations provide a sound basis for assessing and responding to the current 

vulnerabilities in the management and execution of efforts to provide a viable electric power grid. 

The EMP Commission is the most competent and technically credible source of such advice. 

Below, I will elaborate on how I am actively seeking in South and North Carolina a stepping stone 

to achieve his third observation, by taking Texas State Senator Bob Hall's "islanding" approach to a 

more fundamental level. 

It is interesting that when Dr. Graham and l were junior USAF officers at the Air Force Weapons 

Laboratory (AFWL) at Kirtland AFB, NM conducting research on nuclear weapons effects and 

developing simulators to test the nation's strategic systems and their essential command, control 

and communications (C3) systems to assure their viability under nuclear attack, Senator Hall was 

also a USAF junior officer at the Space and Missile Systems Organization (SAM SO) at Norton 

AFB, CA-helping to harden the Minuteman ICBM system, specifically to EMP effects. Our 

efforts were highly classified because all our systems were vulnerable to EM P-as then recently 

discovered on atmospheric nuclear tests. Our EMP knowledge base remained highly classified until 

most were downgraded and published in the 2008 EMP Commission report-see Footnote 16. 

Now we have the opportunity again to cooperate on hardening the electric power grid (and other 

related critical infrastructure }-and to exploit the urgency of effecting change that I believe we all 

feel. This includes overcoming political challenges, which are in fact more daunting than the costs 

of making needed improvements or technical challenges, which were solved a half century ago by 

the Department of Defense {DoD) and its contractors expert in protecting military systems from the 

effects of nuclear weapons. 

6 
27 

POLITICALIBUREAUCRi\ TIC CHALLENGES 

Not the least of the political challenges is associated with ineptness in the responsible DoD agencies 

that have blocked progress-e.g., by stalling the initial startup of the Congressionally re-established 

EMP Commission by almost a year and, as I understand it, continuing to inhibit its effective 

operation. Moreover, DoD is withholding information it learned many years ago in establishing 

threat EMP environmental information standards to protect our strategic systems that our nation's 

power companies now need to develop, deploy and maintain effective hardening designs. 

So, DOE laboratories and other agencies are conducting studies to learn again, under the best of 

conditions, lessons mastered by DoD nearly a half century ago. Under less desirable conditions on 

several fronts-and without the knowledge that comes from a half century of practical experience, 

the current efforts can easily-perhaps predictably-·run amok. 

In the decades when nuclear testing was conducted, the DOE had so little interest in EMP and other 

nuclear weapon effects that the DoD had to pay the DOE to calculate the necessary weapon gamma 

ray and other outputs to allow accurate EMP analyses to be performed by the DoD. Now that the 

DOE and its national laboratories arc searching for relevant missions, both government and private 

monies are going to replicate what the DoD accomplished years ago at considerable taxpayer 

expense. See Dr. Graham's Items 5 and 6, above. 

Moreover, political/bureaucratic problems come from mission conflicts between DoD and other 

government departments and agencies-particularly the Department of Homeland Security (DHS). 

Evidence of these difficulties was graphically illustrated a couple of years ago when then 

Commander of Northern Command (NORTIICOM) Admiral William Gortney made clear he 

understood the significance of the EMP threat (See Dr. Graham·s Items I and 4.) by supporting a 

major program to improve the viability of his mission to provide warning to our strategic forces and 

the President (costing almost a billion dollars) to harden and move key equipment from Peterson 

AFB to his Cheyenne Mountain command center to assure viability of that mission against EMP. 

i\t the same time, little has been done to assure the NORTHCOM's Homeland Defense mission is 

viable in the face of the same EMP attack-not NORTHCOM's job to protect the nation's critical 

civil infrastructure except in commanding our BMD systems. Admiral Gortney indicated his was a 

supporting role to DHS and the Justice Department. I again call your attention to Footnote 9 and 

note that to my knowledge DHS has not even listed EMP among the strategic disaster scenarios 

against which all emergency managers (federal. state and local) are supposed to prepare22 • See 

Footnote 21 that explains Dr. Graham's purpose in his letter to Secretary Perry. Unlike the previous 

DHS Secretary, Secretary Kelley has stated his support tor addressing such EMP and related issues. 

Senator Hall certainly understands many of these political challenges, since this is his second try at 

getting the full Texas Senate to pass needed legislation to harden the Texas Grid-and the Texas 

legislature meets only every other year. Other states have tried and are trying to pass legislation in 

various formats to protect their citizens. But so far, most of their efforts have been blocked by a 

lethargic regulatory, selt~supervising regime and lack of leadership at the federal level-in both the 

legislature and executive branches. And 1 would add, a lack of knowledge of what needs to be done. 

r d also note that NORTHCOM has refused at least two attempts known to me by the SC Adjutant General's office to 

permit the National Guard to include E\1P in its annual Vigilant Guard exercises. So the National Guard upon which vve 

ali depend in major emergencies is unprepared to deal \vith EMP threats. 

7 
28 

In 2013, the first state legislation was initiated by State Representative Andrea Boland and passed in 

Maine, and I understand the subsequent response has been helpful but limited-inhibited by 

pushback from the private sector and a lethargic response by Maine's Public Utility Commission. 

That public record is pertinent for others to exploit. A successful legislative example is Virginia's, 

which I understand is being effectively supported by Dominion Power-perhaps because Virginia's 

major military presence has a collective background that appreciates the EMP threat. A number of 

other states are also considering initiatives, and there are combined positive efforts, such as are 

being pursued by Ohio's American Electric Power, involving II states. 

WHAT TO DO? 

Given these political/bureaucratic difficulties (and others), J concluded several years ago that I 

would never see major progress in dealing with the EMP existential threat in my lifetime, especially 

if the current conditions remain. And I could see no prospect for meaningful improvement. So, I 

decided to try a different approach and work the problem from the "bottom up" ... literally. 

I entered this phase with several biases, based on a lifetime of pertinent experiences, which have 

survived to this day and which guide my assessments and recommendations. 

• I have no confidence that we will ever harden the entire grid, so I believe we have to establish 

priorities-! give top priority to assuring the safety and viability of our -100 nuclear power 

plants that produce about 20-percent of the nation's electricity, and half the electricity of my 

home state South Carolina. Thus, I believe our top priority is to build protected "islands" 

around our nuclear power plants23 . 

• To assure the viability of the nuclear power plants, we must first assure their cooling water 

systems are viable in an indefinite grid shutdown to avoid Fukushima-like disasters. 

• We must assure that sufficient generating and loading conditions provided by the surrounding 

"island" in the grid-and linked with other critically important elements of the grid-are 

available to restart the nuclear power plants--and other power plants, which will shut down to 

protect themselves if the grid goes down. 

• I don't believe anything that isn't regularly tested and subjected to independent critical 

review-effective design and deployment is not enough; truly effective testing and 

maintenance are major challenges. 

• Accomplishing these objectives requires considerable emergency management cooperation at 

the local level-without which there is little hope tor most citizens who today depend on 

electricity for life-line services in our "just-in-time" economy. 

I approached the Electrical Engineering Department Chairman at my alma mater, Clemson 

University, and requested information on faculty who might be interested in my concerns and 

graduates who were employed by Duke Energy-one of the nation's largest companies. if not its 

largest, with whom I could begin working to address the EMP threat to the grid. I want to make 

clear I was not selling anything to or for Duke and would not take money from them if they offered 

it. I just want to cut through the morass described above, and provide hope that my grandkids can 

survive if we experience an EMP attack. I know that all our citizens want this objective met. 

:.:.1 This "Islanding" approach to prioritizing what to harden first is similar to the approach adopted by the DoD in giving 

top to protecting our strategic systems and their supporting command, control and communications systems. 

This was central to our "'deterrent'' policies of the Cold \Var. And vie hardened little military infrastructure 

and csstntia!ly no critical civil inf!·astructure beyond assuring that we could meet that objt:ctive. 

8 
29 

To make a long story short, I developed an excellent relationship with a key professor and several 

Duke engineers who also are concerned about this threat-and we agreed on how we could proceed 

with a meaningful "bottoms-up" program to assure the viability of three Duke Energy power plants 

on Lake Wylie, on the Catawba River that runs between North and South Carolina-and of course 

key transmission infrastructure that interconnects those power plants and others to their customers. 

We refer to this project as the "Lake Wylie Pilot Study," briefly summarized in the following chart. 

,>ttm••nm• Suppm•fllu· f<e,fomtitm Crt'!!'' 

• CummunicatifJI!sl1'raiBJU:Wfatlon 

goods and pcrsoum:l 

• .ltaintulttlinh to ;Valimwl and Stme Gmml 

COSOI'S!I>r at !.•tt\1 HJtk tSC); 

I SCI: allif Ouke 

1:111'1:1:'1'--m t:'fiN<'t't1 h'itlt ,\"alimwl mui ,\tau ( ium'il 

• fdntl(f,\• .<lmrtfalls in nll'l'<'lll nqmbilitlt•s amloutlimr 

plmrv Jar timdy imprmwnenf 

~~t,~::t:~~:;;,~~~·ta lmrden ar .'itfJtkpilfY 

• H;,-,,enlial commuuh:tltlmtf.;, requirt'Wt'Ufs? 

•flow ftl prlH'itlt· minimum f~Hnttial trau~parttlfion? 

• lrtw pravidt•s mi11imum <'SUfllial fuel:' 

I have now been working for nearly two years with Duke Energy engineers to address how best to 

assure we can restart the grid after a major blackout-while giving top priority to assuring the 

safety and viability of our Nuclear Power Plants 24 • Duke Energy's senior management has agreed to 

share broadly the lessons learned from the Lake Wylie Pilot Study. 

In particular, we arc working with local and state authorities and citizens to help Duke engineers 

exploit the most resilient electric power source, the Wylie Hydroelectric Power Plant, to assure 

availability of electricity to the cooling water pumps at the Catawba Nuclear Power Plant, if its 

diesel generator fuel is exhausted and can't be replaced. (See the list of"Needed Operations 

24 Along the way, I discovered that Duke Energy was funding related research at several universities and in cooperation 

with other energy companies. While that research is primarily focused on the eyber threat, EMP concerns will no doubt 

also receive attention. Recently I learned that Duke plans to invest significant funds to modernize and protect their 

power systems over the next 10 years, $13 billion in North Carolina (http://www,utilitydivc,com/ncws/dukc-encrgy-tohardcn-north-carolinas-powcr-system-with-13b-initiative/440524/) and $25 billion in the several states in which they 

have infrastructure http://www .charlotteobscrvcr.com/ncws/busincss/articlc 13 3059044.html . 

9 
30 

Support" and "Key Questions" in the above chart.) The Allen Coal Plant in Gaston County, NC also 

should be available relatively quickly and has a major supply of coal to support operations. 

So, at a top level, the key operations of the Duke infrastructure are being considered and with no 

question Duke Energy intends to assure its power plants are functional after an EMP attack. From 

my perspective, there would likely be problems with SCAD As, especially those that control natural 

gas and petroleum pipeline operations, so that is a remaining concern-at least to me. 

We are working to assure that electricity gets restored to subscribers around the Lake Wylie 

"lsland" in the grid, especially high priority subscribers like the water-wastewater operations that 

are not served directly by Duke Energy intrastructure25 • That service is provided by other utility 

companies and Electric Cooperatives (CoOps) that maintain important grid infrastructure between 

Duke Energy, from whom they purchase electricity, and their subscribers. Moreover, Duke Energy 

engineers need information from these utility companies and CoOps if they are to exploit that set of 

loading conditions to enable rapid restart of their power plant operations serving the general public 

throughout York County and beyond. 

We are progressing well toward this end-engaging with city, county and state officials to assure 

(at least in York County, SC and Gaston and Mecklenburg Counties, NC) that the utility companies 

and CoOps who buy electricity from Duke and distribute it through their own grid infrastructure to 

their customers/subscribers are prepared to deal with a major grid outage. We seck to assure that 

Duke Energy's nuclear, hydroelectric and coal power plants serve the local interests-and that the 

lessons learned are exploited throughout South and North Carolina-and beyond. Our effort should 

serve as a pattern that can be followed in integrating the activities of the several thousand electric 

utilities and CoOps that are key to delivering electricity to their subscribers throughout the nation. 

We plan to engage with others as we progress-as previously noted. I intend to join forces with 

Texas Senator Bob Hall and other friends in Texas as they progress with their legislative initiative 

and related efforts to harden the Texas Grid and especially related to nuclear power plants and 

associated islands in the overall grid. l also intend to engage other states, particularly Pennsylvania 

and lllinois. Like South and North Carolina, they rely heavily on electricity from nuclear plants. 

I also intend to work closely with the National Guard and the Adjutants General of the United States 

because of their key roles in disaster emergency management activities26 • 

Before we began our Lake Wylie Pilot Study in earnest, my Duke Energy partner engineers got 

approval from their front office that the lessons learned would not be treated as "Duke 

Proprietary"-but could be shared with others in the electric power and related sectors. We are 

working with local and county officials and associated utility companies and other CoOps to 

\\ ater-wastcv,'ater 

wastc\vater support. 26 While our SC Adjutant General-a Georgia Tech electrical engineering graduale-·-is on hoard with our Lake Wylie 

ViC have not yet engaged our state legislators to seek a supportive legislative initiative, However. SC State 

and Legislators have indicated to me during the past two years that they would help sponsor such legislation 

when we are ready. The Duke engineers with whom I am working have cleared our project vvith their tt·ont office and 

lessons learned will be shared with all when we are ready. I understand from my Duke partners that they are fully 

engaged in a related NC initiative by their Lt. Governor. 

10 
31 

understand how best to assure infrastructure connectivity to enable a Black Start following a major 

grid shutdown, beginning with the Lake Wylie "Island" in the grid. 

South Carolina is one of the few states (joined only by Wisconsin when last I checked) focusing a 

statewide effort associated with NERC's November GRIDEX-IV national exercise on responding to 

cyber and physical attack threats. I believe the lessons learned will be helpful in extending, again 

from the bottom up, our Lake Wylie efforts. Therefore, we are also engaging with several other 

counties in this national exercise to build the relationships to share our lessons learned. 

Note, there are several thousand utility companies and CoOps in the United States-so solving this 

important problem for that integrated "crazy quilt" distribution system is very complicated. 

I have serious doubts that 1 will see a solution result in my lifetime from a "top-down" federal or 

stale initiative. This is not to argue against such initiatives-which are important at least for 

consciousness-raising purposes. But I do worry that at best they have been proven to be very 

inefficient in producing serious progress in actually dealing with a truly existential threat. 

I'm excited about our progress in working the problem from the bottom-up thus far-with a 

particular focus on assuring viable water-wastewater services to local citizens, and will be sharing 

more in!onnation in the future, especially with the lessons learned on how best to deal with the 

political issues that have for more than a decade confounded our collective progress. 

My final comment is a lesson I have learned from my entire career: Effectively designing, 

deploying and operating any complex system requires a competent "Red Team" with access to all 

design, deployment and operations information, and which can challenge at the top level all efforts 

and report findings to the top management27 . 

In my opinion, the EMP Commission should be chartered to play that role-indefinitely, and it 

should report directly to the President through an appropriate White House office hosting secretariat 

services. 

Thank you for your interest and attention. 

27 During my watch as SDI Director (1990-93).1 voluntarily sent several hundred million dollars trom my live year 

budget to the Defense Special Weapons Agency (now the Defense Threat Reduction Agency) with no strings attached, 

except that the funds be spent to develop an independent competent assessment capability that could provide needed 

independent "Red Team" inputs to me (and my boss, the Secretary of Defense) on our BMD acquisition efforts. My 

distinct impression is that DTRA 's capability and interest is a pale shadow of the DS\V A ·sin that era a quarter century 

I have no idea vvhether the key BMD systems developed under acquisition programs that I began (our groundinterceptors in Alaska and California, our BMD system, our Patriot System or the THAAD system nov.' 

being deployed in South Korea· ···and their command, control and communications systems) are confidently 

hardened against EMP, but without question. they certainly should be. 

11 
32 

The CHAIRMAN. Thank you, Ambassador. 

Ms. Durkovich, welcome. 

STATEMENT OF CAITLIN DURKOVICH, DIRECTOR, 

TOFFLER ASSOCIATES 

Ms. DURKOVICH. Thank you. 

Good morning, Madam Chair and members of the Committee. 

Thank you for inviting me to testify today on protecting our energy 

infrastructure from the threat posed by electromagnetic pulse. 

My name is Caitlin Durkovich. I had the honor of serving eight 

years in the National Protection and Programs Directorate (NPPD) 

at the Department of Homeland Security, first as the Chief of Staff 

and from May of 2012 to January of 2017 as the Assistant Secretary of Infrastructure Protection. NPPD leads the national effort 

to protect and enhance the resilience of our nation’s physical and 

cyber infrastructure. I transitioned from government to Toffler Associates, a future-focused strategic advisory firm that architects 

better futures for public and private sector clients. 

Over my nearly 20-year career in homeland security, I have seen 

critical infrastructure public-private risk management redefined to 

address emerging, complex issues from violent extremism to complex mass attacks, cybersecurity grid and GPS resilience, extreme 

weather and electro and geomagnetic disturbances. 

I have co-chaired interagency task forces that have integrated 

the private sector into government strategies, including those that 

are most relevant here today—the Joint U.S.-Canada Electric Grid 

Security and Resilience Strategy and the National Space Weather 

Strategy. 

There is no doubt that we live in a dangerous world. State and 

non-state actors, insiders and promulgators of disinformation are 

growing in kind and consequence. Borders no longer protect us 

whether our shores or the fences and walls of our organizations. 

We have built a complex ecosystem where disruption in one node 

can ripple across the system and where threats are not bounded to 

one sector or one industry nor can we protect against every threat 

and secure every building system and network. Our country is too 

big; our infrastructure too interdependent; the cost too expensive; 

and, the outcome would alter our way of life. 

This is why we are in the business of risk management. Think 

of a matrix where the x and y axes are increasing likelihood in consequence, respectively. A denial of service attack is highly probable, 

but the impact to a company and its operations is minimal. 

Most natural disasters are high likelihood and low consequence. 

Superstorm Sandy or a 9.0 Cascadia Subduction Zone event are exceptions and flip, low likelihood, high consequence. A cyberattack 

against industrial control systems like the December 2015 attack 

on the Ukrainian power grid, lower probability than denial of service, but certainly more consequential. In 1859 Carrington Light 

GMD event. As Speaker Gingrich said, we are long overdue. And 

so, I would say it is more likely and certainly high consequence. 

There are half a dozen more risks on that matrix, including a highaltitude electromagnetic pulse, and we place it at a very low probability but high consequence. 
33 

All of the risks on this matrix must be managed. Since critical 

infrastructure is largely owned and operated by the private sector 

there are finite resources in a world where you have a business to 

operate, shareholder obligations, regulatory costs and rate recovery, just to name a few. 

I want to be clear. We have not ignored the threat of an EMP. 

Industry and government are working hand-in-hand to better understand the impacts of EMP. The work that EPRI is doing is critical to understanding how the systems and its parts would be affected. This critical modeling can help inform where investments 

and shielding will have the maximum value and what operational 

procedures can mitigate voltage collapse. And much of this effort 

can be applied to mitigating the consequences of a GMD where we 

will have time to put measures in place and manage flow thanks 

to improved space weather forecasting and alerting. 

Equally important is the fact that we understand an EMP, like 

many threats and hazards, is sector agnostic. Disruption to communications during incidents hampers response and restoration efforts. Malicious actors understand this, and Mother Nature is 

undiscerning. 

There is debate about the sophistication of the attack on the 

Metcalf Substation that supplies power to Silicon Valley, but the 

perpetrators knew enough to cut the fiber lines that controlled 911 

and downstream communications. A telephone denial of service attack hampered the ability of customers to call and utility operators 

to talk to each other in the Ukrainian incident. 

An EMP or GMD will impact communication systems and data 

centers and, therefore, command and control. To industry’s credit, 

they are looking beyond prioritized calling services as a contingency plan but it illustrates why we cannot take a silent approach 

and must understand the vulnerabilities caused by the intersections of these sectors. 

This complex risk environment is what has given way to the public/private partnership. While government brings important capabilities to the table, information sharing, private sector clearances, 

research and modeling, war gaming, industry is heavily invested in 

ensuring its reliability and resilience. Disruptions impact their bottom line, their brand and their industry. 

It is why the Joint U.S.-Canada Electric Grid Security and Resilience Strategy, the National Space Weather Strategy and the Joint 

Electromagnetic Pulse Resilience Strategy and corresponding action plans are critical. They lay out high-level goals for government 

and industry to guide action and investment, to enhance resilience 

and accelerate recovery from these types of events. 

In conclusion, we are managing a complex risk environment and 

cannot protect against every threat and secure every asset. There 

is no one-size-fits-all approach. The solution requires a whole of 

community risk-based approach focused on mitigation planning and 

investment in a modern and secure infrastructure that is resilient 

to the threats of today and tomorrow. 

Thank you, and I look forward to your questions. 

[The prepared statement of Ms. Durkovich follows:] 
34 

Testimony of 

CAITLIN DURKOVICH 

Director, Toffler Associates 

Former Assistant Secretary, Infrastructure Protection, 

National Programs and Protection Directorate 

Department of Homeland Security 

Submitted to the 

SENATE ENERGY & NATURAL RESOURCES COMMITTEE 

"For the May 4, 2017 Heariug 

"To Examiue the Threat Posed by Electromagnetic Pulse and Policy Options to Protect 

Energy Infrastructure" 

Chairman Murkowski, Ranking Member Cantwell, and members of the Committee, thank you 

for inviting me to testify at the hearing today, ''To examine the threat posed by electromagnetic 

pulse and policy options to protect energy infrastructure and to improve capabilities for adequate 

system restoration." 

My name is Caitlin Durkovich. I had the honor of serving eight years in the National Protection 

and Programs Directorate at the Department of Homeland Security (DHS), first as the Chief of 

Staff and from May of20 12 to January 20 I 7, as the Assistant Secretary of Infrastructure 

Protection. NPPD leads the national effort to protect and enhance the resilience of the nation's 

physical and cyber infi·astructure. 

l have transitioned from government to Toffler Associates, a future-focused strategic advisory 

firm that architects better futures for public and private sector clients around the globe with an 

unwavering commitment to be the catalyst for change. 

Over my nearly twenty-year career in homeland security, I have seen critical infrastructure 

public-private risk management redefined to address emerging, complex issues from lone 

offenders to complex mass attacks, cybersecurity grid and GPS resilience, interdependencies, 

electromagnetic pulse (EMP) and severe geomagnetic disturbances (GMDs), and security-bydesign. I have co-chaired several interagency task forces that have integrated the private sector 

into government strategies, including those that are most relevant today- the Joint US-Canada 
35 

StrafeF;yfor Electric Grid Security and Resilience (December 2016) and The National Space 

Weather Strategy (October 20 15). 

There is no doubt we Jive in a dangerous world. State and non-state actors. cybcr threats, 

unbounded di:-.astcrs, lone offenders. insiders. and promulgators ofdisinformation arc growing in 

kind and consequence. These threats and our vulnerabilities to them- transcend political 

treaties. geographic borders. and corporate lines of business. blurring the lines between public 

and private accountability and responsibility. It is the private sector, which owns and operates 

most of our critical intrastructurc. that must invest in and manage the risks and often intertwined 

consequences posed by an increasingly dynamic threat environment. 

The energy sector in particular faces a variety of threats and hazards, largely driven by the 

increasing sophisticated threat actors with intent and capability as well as the interdependencies 

of the infrastructure systems, including the increasing reliance on digital infrastructure as the 

electric grid transitions fi·om an analog system to a digital system to improve efficiency. The 

bottom line is the risk to digital and physical infrastructures has grown and our critical 

infrastructure is more vulnerable than it was a few decades ago. 

My colleagues in government have testified before other committees about how the publicprivate partnership views EMP, and my time out of government has not changed my 

understanding of the threat or my perspective; therefore, I will leverage the work ofDHS and my 

colleagues within the DHS Office ofCyber and infrastructure Analysis. 

Background on EMP 

An EMP is the burst of electromagnetic radiation created, for instance, when a nuclear weapon is 

detonated or when a non-nuclear EMP weapon is used. EMPs can be high frequency, similar to a 

flash of lightning, or low frequency, similar to an aurora-induced phenomenon. The 

consequences of an EMP can range from permanent physical damage to temporary system 

disruptions, and can result in fires, electric shocks to people and equipment, and critical service 

outages. 

There are two general classes of EMP of concern: (I) Nuclear sources of EMP, such as High 

altitude EMP (HEMP), and (2) Non-Nuclear sources ofEMP (NNEP). HEMP results from a 

nuclear detonation typically occurring 15 or more miles above the Earth's surface. The extent of 

HEMP effects depends on several factors including the altitude of the detonation, the weapon 

yield, and whether it was designed for EMP effects. On the ground, effects may be diminished 

by the electromagnetic shielding, or "hardening," of assets. A high-altitude burst could blanket 
36 

the entire continental United States and cause widespread impacts to multiple sectors, including 

to lifeline sectors, such as the energy and communications. HEMP threat vectors can originate 

from a missile, such as a sea-launched ballistic missile; a satellite asset; or a relatively low-cost 

balloon-borne vehicle. 

Non-Nuclear EMP (NNEP) can be created by sources, such as Radio Frequency Weapons or 

Intentional Electromagnetic Interference devices, which arc designed to produce sufficient 

electromagnetic energy to burn out or disrupt electronic components, systems, and networks. 

NNEP devices can be either electrically-driven, where they create narrowband or wideband 

microwaves, or explosively-driven, where an explosive is used to compress a magnetic field to 

generate the pulse. The range of an NNEP is short (typically less than 1 kilometer) and Faraday 

casings with line filters and surge arresters can mitigate much of the EMP effects. 

Potential Impacts to Critical Infrastructure from EMP 

We do not fully understand how an EMP event would impact electrical infrastructure, and it is 

the subject of ongoing analysis. In some of its forms, EMP could cause widespread disruption 

and serious damage to electronic devices and networks, including those upon which many 

critical infrastructures rely. There is uncertainty over the magnitude and duration of an electric 

power outage that may result from an EMP event due to ambiguity regarding the actual damage 

to electric power assets from an event. Any electric power outage resulting from an EMP event 

would ultimately depend upon several unknown factors and effects to assets that are challenging 

to accurately model, making it diftlcuit to provide high-specificity information to electric system 

planners and system operators. These variables include characteristics such as the EMP device 

type, the location of the blast, the height ofthe blast, the yield of the blast, and design and 

operating parameters of the electric power system subject to the blast. Secondary effects ofEMP 

may harm people through induced fires, electric shocks, and disruptions of transportation and 

critical support systems, such as those at hospitals or sites like nuclear power plants and chemical 

facilities. 

In the development of The Nalional Space Weather Strategy, we recognized that the growing 

interdependencies of critical infrastructure systems have increased potential vulnerabilities to 

EMPs and GMDs. Cross sector protection and mitigation efforts to eliminate or reduce EMP and 

GMD vulnerabilities are essential components of national preparedness. Protection focuses on 

capabilities and actions to eliminate vulnerabilities to EMP, and mitigation focuses on long-term 

vulnerability reduction and enhancing resilience to disasters. Together, these preparedness 
37 

missions frame a national effort to reduce vulnerabilities and manage risks associated with 

EMPs, GMDs, and other unbounded events. 

Government and Industry and Collaboration 

More than two decades of critical infrastructure programs and policies has fostered 

unprecedented collaboration between government and industry to mitigate the consequences of 

low probability, high consequence events, including EMP. 

DHS continues to devote resources to address EMP risks, largely in three areas (I) risk 

assessment and analysis, (2) communication and coordination of threat information, and (3) 

research and development to mitigate EMP risks. NPPD, the Federal Emergency Management 

Agency, and the Science and Technology Directorate are working with the critical infrastructure 

community to ensure it has information to make critical decisions, and can respond to, assist 

recovery and mitigate the consequences of a potential EMP attack. 

My fellow witnesses will testify to the scope ofetTorts industry is undertaking to continue to 

improve grid resi lienee to all-hazards. They range from continued research and development, 

mutual assistance and spare parts programs, supplemental operating strategies, and full-scale 

cross sector exercises. 

Critical Infrastructure Risk Management 

It is important to emphasize, however, that critical infrastructure, including the electric sector, 

takes a holistic approach to assessing and mitigating risks from not only EMP, but from cyber 

attacks, physical sabotage, and natural disasters, all of which can result in disruptions to their 

operations. The partnership between industry and government, which includes information 

sharing, capability development, training and exercises, and interoperable plans, is even more 

essential as our Nation continues to face an increasingly complex threat environment. 

Conclusion and Recommendations 

EMP is one of many threats to the functions, systems, and networks that underpin our national 

security, economic prosperity, and American way oflife. From cyber espionage and sabotage, to 

the convergence of cyber and physical systems, to insider threats, and to EMPs and GMDs, 

owners and operators of critical infl'astructure have an obligation to manage these persistent 

threats. However, the solution requires a whole of community effort that is focused not on one 

threat but on a broad range of threats. These challenges demand industry and government work 
38 

together to both develop mitigation plans and to invest in a modern and secure infrastructure that 

is resilient to the threats of today and tomorrow. 

You can help by continuing to support national programs that strengthen public-private 

collaboration and enable the critical infrastructure community to efficiently and effectively 

manage the complex risk environment, and by continuing to advocate for a secure and resilient 

critical infrastructure. 

Chairman Murkowski, Ranking Member Cantwell, and members of the Committee, thank you 

again for the opportunity to appear before you today. I look forward to your questions. 
39 

The CHAIRMAN. Thank you, Ms. Durkovich. 

Mr. Manning, welcome. 

STATEMENT OF ROBIN E. MANNING, VICE PRESIDENT, TRANSMISSION AND DISTRIBUTION, ELECTRIC POWER RESEARCH 

INSTITUTE 

Mr. MANNING. Thank you, Madam Chairman, members of the 

Committee. Good morning. 

I want to share with you a bit of history, if I can. I am a Vice 

President of Transmission and Distribution for the Electric Power 

Research Institute, but also spent 30 years at Duke Energy and another six at the Tennessee Valley Authority (TVA). And through 

this time my responsibility was leading construction, operation and 

maintenance of energy infrastructure. 

So, as the Chairman put it so well earlier, I kept the lights on 

across the United States. As the leader of TVA’s transmission organization in the 2008–2009 timeframe as I read the EMP Commission report, I struggled to understand how I could take the plethora of information that was available on EMP and practically apply 

it to create some sort of a plausible approach for risk management 

associated with TVA’s system. 

And that’s exactly what EPRI is attempting to do as we are now 

one year into a three-year research project, began in April of 2016. 

Our project objective is to develop cost-effective mitigation tools, to 

develop recovery options for utilities and to form a basis for decision-making that provides utilities, like the TVA, the information 

that is necessary to effectively protect their customers from the 

EMP threat. 

This project now has financial support from 57 U.S. utilities, 

making this project one of the most widely-supported collaboratives 

ever at EPRI. We’re also collaborating very closely with the U.S. 

Department of Energy with national labs and the U.S. Department 

of Defense. 

We have seven tasks on this project. Many of these tasks are 

being completed in parallel with various expected completion dates 

over the remaining two years of the project. We are seeking greater 

characterization of the HEMP threat as it relates to electric infrastructure; we’re investigating specifically how EMP propagates and 

how it couples to power systems; we’re testing that equipment to 

understand at what level do we begin to see damage from EMP 

events; and then we’re combining the threats and the 

vulnerabilities to understand a more complete picture, a holistic 

picture of EMP impacts to infrastructure. But together this information provides methodologies and tools to support risk-informed 

decision, and of course, it’s our intention to communicate our research findings to public policymakers and other stakeholders 

throughout the process. 

For example, in February we released publicly a report assessing 

the impacts of a HEMP-generated, E3 energy wave on bulk power 

transformers. We advanced a series of a test nuclear blast across 

the United States, 11 different locations and assessed the value of 

each of those. We used advanced modeling assessment techniques 

as well as conservative assessment criteria and conservative engineering judgments throughout. 
40 

The results of this study indicated that damage to a large number of bulk power transformers from E3 is unlikely. Even so, the 

results of the assessment should not be interpreted to mean that 

HEMP or even the E3 would not adversely affect bulk power system reliability. The potential for widespread outages due to voltage 

collapse or the combined effects of E1, E2 and E3 are still being 

investigated. 

Certainly impacts from HEMP are real; however, evaluating the 

effects of such events on complex systems like our electric power 

grid requires concrete, scientifically-based analysis from people who 

understand the power system. With greater understanding, costeffective mitigation and/or recovery options can be developed and 

deployed. 

The utility industry is poised to take further action, and more 

scientific research enables these actions to be both appropriate and 

cost effective for consumers. 

At EPRI we are committed to providing sound science-based solutions to these complex problems and will continue to offer technical 

leadership and support to the electricity sector to public policymakers and other stakeholders to enable safe, affordable, reliable 

and environmentally responsible electricity to the people of the 

United States. 

Thank you for your time. That concludes my testimony. I look 

forward to your questions. 

[The prepared statement of Mr. Manning follows:] 
41 

Written Testimony 

Hearing of the U.S. Senate Energy and Natural Resources Committee 

Robin E. Manning 

Vice President, Transmission and Distribution 

Electric Power Research Institute 

"Hearing to examine the threat posed by electromagnetic pulse and policy options to protect 

energy infrastructure and to improve capabilities for adequate system restoration" 

May 4, 2017 

The Electric Power Research Institute (EPRI) conducts research and development relating to the 

generation, delivery, and use of electricity for the benefit of the public. An independent, nonprofit organization, EPRI brings together its scientists and engineers, as well as experts from 

academia and industry, to help address challenges in electricity, including reliability, efficiency, 

affordability, health, safety, and the environment. EPRI's members represent approximately 90 

percent of the electricity generated and delivered in the United States, and international 

participation extends to more than 30 countries. 

The subject oftoday's testimony is EPRI's research efforts related to electromagnetic pulse 

(EMP) events, including naturally occurring geomagnetic disturbances (GMD) as well as 

electromagnetic pulse (EMP) events, specifically high altitude EMP, or HEMP. EPR! has been 

researching GMD for many years with significant applications now implemented across the 

electric industry. Implications and solutions for EMP and HEMP are less understood. Much of 

the available information is not specifically applied to electric utilities, making it very difficult 

for utilities and regulators to understand effective options for protecting energy infrastructure. 

This testimony provides an overview ofEPRI's research activities related to GMD, and a more 

detailed description of our EMP research efforts as we seek to better inform the issue with a firm 

technical basis for decision making. 

GMD Research 

During geomagnetic disturbance (GMD) events, magnetic field variations at the earth's surface 

drive low-frequency electric currents along transmission lines and through transformer windings 

to ground. These geomagnetically induced currents (GIC) cause half-cycle saturation of 

transformers leading to harmonic generation, increased reactive power losses, and heating of 

transformer windings and structural components. These effects arc real, and have been observed 

in the past. For example, during the March 1989 geomagnetic storm, Hydro-Quebec experienced 

a blackout resulting from the effects ofGMD-related harmonics, and a generator step-up unit 

(GSU) at Salem Nuclear Power Plant in New Jersey was damaged from resulting hotspot 

Page 1 of8 
42 

heating. Several other effects were observed in the United States and Canada, for example 

tripping of capacitor banks, but these did not result in any significant reliability impacts 1

• 

EPR! recognizes the potential impacts of severe GMD events, and has been involved in GMDrelated research for nearly four decades2

• Some ofEPRI's research activities in this area include: 

• developing sensors and a support network for measuring GIC; 

• developing software tools, models and guidelines to assess the impacts of severe GMD 

events on the bulk-power system; 

• improving the fidelity of existing models (e.g. earth conductivity); 

• improving understanding of potential impacts orGMD events on bulk-power system 

components; 

• evaluating mitigation options and their application; and 

• supporting the development of benchmark GMD events used in assessments. 

Because EPRI's research in the GMD area is expansive, only current activities will be addressed. 

Geomagnetic Field Monitoring 

EPRI currently has a research project underway to install three axis magnetometer sensors 

between existing magnetic observatories operated by the U.S. Geological Survey (USGS) to 

improve magnetic field resolution throughout the United States. Measurement data will be used 

to validate deep earth conductivity models, and improve understanding of local geological 

factors that can affect the geoelectric tleld induction process. 

SUNBURST Network 

The EPRI SUNBURST network is both an organized method for measuring gcomagnetically 

induced currents (GICs) and a source of data for continuing research studying the cause, effects 

and mitigation ofGIC impacts on electrical power systems. While the primary focus of this 

research is operating the monitoring network, the data collected in this project will be used for 

feedback into new prediction models that will serve as advance warnings, that is, the NASA 

Solar Shield project. The SUNBURST project also supports an annual event where relevant 

scientists from the field of solar phenomena/space weather come together to discuss common 

issues and concerns related to GICs. 

The SUNBURST network consists of a consortium of member utilities where near-real-time 

continuous monitoring of the GJC flowing in the neutral of large power transformers is 

performed. Over the last decade, EPR! has accumulated a body of data and experience about 

correlations between space weather and G!C tlows in the grid. 

'Investigation ofGeomagnetica/ly Induced Currents in the Proposed Winnipeg-Dul/uth-Twin Cities 

500 kV Transmission Line. EPR!, Palo Alto, CA: 1981. EL-1949 

Page 2 of8 
43 

New GIC Sensor 

One of the limitations of measuring GIC using current technology (e.g. SUNBURST) is that the 

monitoring location must be the neutral of the transformer. Depending on the type of 

transformer, e.g. an autotransformer, a neutral connected GIC node may not provide the 

observability necessary to determine the GIC flows that could affect power system operation. To 

till this gap, EPRI has recently developed a sensor that is capable of measuring GIC flows in 

energized conductors. Measurement ofGIC in energized AC (alternating current) transmission 

lines and transformer windings improves observability ofthe behavior and effects ofGIC on the 

bulk-power system. In addition, GIC flows through interconnections and in some cases, remote 

transformers can be measured directly. This will lead to developing more effective network 

boundary models, and closer representation of actual GJC conditions when assessing impact to 

transformers. 

Current Research in Grid Operations & Planning Area 

Harmonics studies are an integral part of any GMD vulnerability assessment, and as such, are a 

key component of related reliability and planning assessments and associated regulatory 

requirements, e.g. NERC TPL-007-1 standard. However, commercially-available software tools 

or industry guidelines necessary to perform such assessments are limited. To till this gap, EPRI 

is developing an open source software tool that can be used to perform GMD-related harmonics 

studies. Additionally, guidelines for performing assessments to determine the potential impacts 

of GMD-related harmonics on the bulk-power system are being developed. 

EMP Research 

Electromagnetic pulse (EMP) attacks and geomagnetic disturbance (GMD) events are often 

discussed together when evaluating potential impacts on the bulk-power system and approaches 

for improving system resiliency. While both events are considered high-impact low-frequency 

(HILF) events (along with physical attacks, severe storms, earthquakes, and other similar 

events), there are very important differences that should be considered when evaluating 

resiliency improvement priorities and investment decisions. 

The high-altitude detonation of a nuclear weapon can generate a large electromagnetic pulse 

(referred to as a high-altitude EMP or HEMP) that is comprised of three components: E I, E2 and 

E3. Depending on weapon yield and height of burst the resulting EMP can impact large 

geographical areas such as the size of an electrical interconnection. The early-time pulse, E 1, 

refers to a nearly instantaneous (rise times are on the order of2.5 nanoseconds or 2.5 billionths 

of a second) large magnitude (50 kV/m) pulse that can result in damage to electronic 

components and electric infrastructure. The intermediate-time pulse or E2, refers to the short 

duration pulse which has characteristics similar to lightning although the magnitude of E2 is 

much lower(- 0.1 kV/m) and the way in which it couples into electric infrastructure is different. 

The latter component, magnetohydrodynamic electromagnetic pulse (MHD-EMP) or simply E3 

is similar to a severe GMD event, and can drive low frequency, geomagnetically-induced 

currents (GlC) in transmission lines and power transformers. However, there are two key 

Page 3 of8 
44 

differences between E3 and GMD. First, E3 from a single high-altitude detonation would not 

generate planetary-scale effects like a severe GMD event can. Secondly, the magnitude and 

duration of E3 are significantly different. The magnitude of E3 can he much higher than that of 

a severe GMD event; however, the duration of E3 is much shorter lasting only a few minutes as 

compared with days in the case of a severe GMD event. As with severe GMD events, potential 

impacts from E3 range from voltage collapse to increased hotspot heating in bulk-power 

transformers. 

EMP Research Project Description 

HEMP events are a growing concern in the energy business. While the industry has 

worked to develop effective responses to GMD, little definitive work has centered on the effects 

of a HEMP attack. Numerous constituencies are pressing to ensure the electric power system is 

more resilient to a large HEMP event, but technical information is inconsistent and options to 

increase resilience through hardening and recovery are not well-defined. Some proposed 

approaches are high-cost and lack the technical basis to substantiate their viability. To fill this 

gap. EPRI initiated a three-year research project in April 2016. currently with financial support 

from fifty-six electric utilities. to improve understanding of the potential impacts of HEMP on 

the bulk-power system and develop cost-effective mitigation options. The financial support of 

EPRI's members demonstrates the importance to them of providing scientific and technical 

analysis of this issue for the bcnetit of the public. 

As a part of this research project EPRI is collaborating closely with the U.S. Department of 

Energy (DOE), national laboratories, and the U.S. Department of Defense (DoD). 

The EPRI EMP project is comprised of7 tasks which are as follows. 

Task 1 -HEMP Threat Characterization 

As a part of the threat characterization task, we are: 

• identifying the state of knowledge of unclassified HEMP research, 

• identifying conservative (bounding) HEMP waveforms (magnitude, spatial and time 

dependent characteristics, etc.) that can be used to assess the potential impacts on bulkpower system components, and 

• investigating the physics of HEMP propagation and coupling to power system 

infrastructure. 

As a part of this research, all three components of the HEMP environment are being evaluated, 

i.e., El, E2, and E3. 

In September 2016, EPRI released its first report3 associated with this task which is a 

compendium describing the state of knowledge of HEMP research that is relevant to the electric 

'High-Altitude Electromagnetic Pulse E.l.fi?Cts on Bulk-Power Systems: State of Knowledge and 

Research Needs. EPRI, Palo Alto, CA: 2016. 3002008999. 

Page 4 of8 
45 

power industry as well as a suite of unclassified HEMP environments that can be used in power 

system assessments. 

We are currently developing models to simulate coupling of E l/E2 into transmission 

infrastructure (substation bus work, control cables, control houses, etc.) and are performing an 

analysis of a transmission substation to determine impacts of E 1/E2 on equipment. Modeling 

results will also be used to inform equipment testing and mitigation efforts. Simulation work has 

begun and will continue into 2018. EPRI is currently working with Lawrence Livermore National 

Laboratory (LLNL) to further research in this area. 

Additionally, an important component of this research is to develop tools that utilities can usc to 

perform their own assessments. To that end, EPRI is developing software tools and modeling 

guidelines that can be used by utilities to simulate the coupling of an El pulse into overhead and 

underground conductors and/or control cables. The beta version of the overhead conductor coupling 

tool is expected to be tinishcd by the fourth quarter of2017. 

Task 2- Electric Infrastructure EMP Vulnerability 

This task is identifying the vulnerability of transmission systems and support assets (protection 

and control systems, communications, SCAD A, cables, transformers, insulators, etc.) exposed to 

the HEMP threat defined in Task 1 HEMP Threat Characterization by performing laboratory 

tests. To facilitate high-volume EMP testing of components, EPRI is building two EMP test labs 

and updating our high-voltage test lab in Lenox, MA to test systems and components by 

subjecting them to synthetic EMP pulses (E 1 ). Equipment testing will include both radiated and 

conducted transients. Testing of protection and control (P&C) systems to determine impacts of 

El is initial priority. Testing is expected to begin by the second quarter of2017 with initial 

results possible by the end of the year. 

In addition to performing tests internally, EPRI is also partnering with Sandia National 

Laboratory and Little Mountain Test Facility to perform additional E 1 testing of P&C 

equipment. 

Task 3- Electric Infrastructure Impacts 

This task is assessing the potential impacts of a HEMP attack on the bulk-power system by 

combining the modeling results of Task 1 with the equipment testing results of Task 2. 

Assessment techniques, models and tools for assessing the impacts of a HEMP attack are also 

being developed. 

The lirst of many studies has been completed, and will be described in more detail later in this 

testimony. A report4 assessing the potential effects ofE3 on U.S. bulk-power transformers was 

released in February 2017. A companion report assessing the potential impacts ofE3 on the 

stability of the bulk-power system is expected to be finished by the third quarter of2017. 

4 J1agnetohydrodynamic Electromagnetic Pulse .A,s·sessment of the Continental liS'. Electric Grid: Geomagnetical!y 

Induced Curren/ and Transformer Thermal Analysis. EPRI, Palo /\Ito, CA:20 17. 3002009001 

Page 5 of8 
46 

The results of the first El threat assessment are expected by the end of the year. 

Task 4- Mitigation. Hardening and Recovery 

This task is assessing various mitigation and hardening approaches that can be employed to 

reduce the impacts of HEMP on bulk-power system reliability. Potential unintended 

consequences of various mitigation and hardening strategies are being evaluated. Enhanced 

recovery procedures/plans are being developed. 

As an initial step, EPRI is developing interim guidance on hardening substations using 

information provided in relevant IEC5 and military standards. This is only a first step. and EPRI 

is not recommending utilities harden to these standards. Future research efforts aim to develop 

cost-effective hardening and mitigation solutions that are relevant to electric power 

infrastructure. Interim guidance is expected to be completed and made available to project 

members by the third quarter of2017. 

Task 5- Risk-based Decision Support 

This task is developing methodologies and tools to support risk-informed decisions regarding the 

implementation of HEMP hardening and mitigation measures. A framework tor assessing the 

relative benefits of various hardening and mitigation approaches will be developed. Support 

tools designed to aid in decision making will be developed as a part of this task. 

Task 6- Trial Implementation 

Once hardening measures have been identified. supporting member utilities will have the 

opportunity to evaluate implementation on aspects of their systems. This task will develop a 

collection of leading industry practices with regards to HEMP mitigation and hardening. 

Applications of various assessment techniques and mitigation options will be catalogued, and the 

effectiveness and lessons learned will be communicated. 

Task 7- Project Member and Stakeholder Communication 

An important aspect of this research project is communicating the results to our supporting 

members and stakeholders as appropriate. This task is developing communications to inform of 

the background and potential impacts of HEMP, and appropriately share new learning in a timely 

manner. 

February, 2017 Report: E3 Assessment (if the Continental U.S. Electric Grid 

GIC generated by E3 resulting from a HEMP attack can cause additional hotspot heating in 

windings and structural parts of bulk-power transformers. If heating is severe enough, it can 

cause damage to the transformer. The loss of hundreds of bulk-power transformers could create 

an environment where system recovery is not possible in a timely manner resulting in long-term 

5 IEC is the International Electrotechnology Commission- an international standards organization 

Page 6 of8 
47 

blackout. Thus, one of the first steps in this three-year research project was to evaluate the 

potential impacts of E3 on bulk-power transformers. 

Past research performed by Oak Ridge National Laboratories (ORNL) during the mid-late J 980's 

through early 1990's and late 2000's evaluated the potential impacts ofE3 on bulk-power 

transformers; however, the results of the ORNL research had conflicting conclusions. Earlier 

ORNL research6 concluded that E3 would not result in significant damage to bulk-power 

transformers while a later research repore concluded that transformer damage was likely, and 

that up to 100 transformers could be damaged depending on the target location. 

The purpose of the EPRI study was to determine, using advanced transformer models that were 

not available at the time of the ORNL research, whether or not a significant number (hundreds) 

of bulk-power transformers would experience thermal damage from a single E3 event. More 

simply, the study sought to answer the question, "if a HEMP attack occurred, would there be 

enough bulk-power transformers le11 to facilitate system recovery?" 

The fundamental approach to the EPRI study was similar to that adopted by the North American 

Electric Reliability Corporation (NERC) to assess the potential impacts of severe geomagnetic 

disturbance (GMD) events on bulk-power transformers. First, the electric field environment 

necessary for calculating GIC flows was identified and a direct current model of the 

interconnection-wide system was assembled. For this study, a publicly available E3 environment 

along with a model of the United States bulk electric system was used to calculate the GIC flows 

in the transmission system that would result from a single, high-altitude detonation over the 

continental United States (CONUS). GIC calculations were then performed assuming weapon 

detonation over I I separate locations in the CONUS. The resulting time-series GIC flows were 

then used to c.ompute the time-series hotspot temperature of each bulk-power system transformer 

included in the interconnection-wide assessment using physically-based transformer models. The 

maximum instantaneous hotspot temperatures were then evaluated against conservative 

temperature limits that were based on an assumed condition-based GIC susceptibility category of 

the entire transformer fleet. The number of transformers that were identified as exceeding the 

specified temperature limits were then combined with the probabilities of a given transformer 

being in one of the three specified categories to estimate the expected number of bulk-power 

transformers to be at potential risk of thennal damage. Additionally, the potential for thermal 

damage caused by circulating harmonic currents in the tertiary windings of large 

autotransformers was also evaluated. 

The EPRI study found that although a significant number of transformers (hundreds to 

thousands) could experience G!C flows greater than the 75 amps/phase screening criteria 

adopted from NERC TPL-007-1, only a small number (3 to 14 depending on the target location 

evaluated) of these transformers were found to be at potential risk of thermal damage. In 

addition, the at-risk transformers were found to be geographically dispersed. 

'Electromagnetic Pulse Research on Electric Power Systems: Program Summary and Recommendations. Oak Ridge 

National Laboratories. Oak Ridge, TN: 1993. ORNL,6708. 7 Meta-R-321. The Late-Time (E3) High-Altitude Electromagnetic Pulse (HEMP) and Its Impact on the U.S. Power 

Grid. Meta tech Corporation, January 201 0. 

Page 7 of8 
48 

The results of this study agree with earlier work performed by ORNL which indicate that the 

failure of a large number (hundreds) of bulk-power transformers from E3 is unlikely. The 

assessment results can be used to help quantify the overall risk of E3 impacting the bulk-power 

system (interconnection-level assessment), but they should not be interpreted to indicate E3 will 

not affect bulk-power reliability since the potential for widespread outages due to voltage 

collapse or the synergistic effects ofEI, E2 and E3 are still being investigated. Additionally, 

because of the number of conservative assumptions that were required due to the lack of asset 

specific data, the results should not be used to inform investment decisions at individual utilities. 

A companion study to the G!C and transformer thermal assessment, an analysis determining the 

potential for voltage collapse resulting from E3, is expected to be completed by the third quarter 

of2017. Future research will be aimed at improving the assessment process to include the 

synergistic effects ofEI, E2 and E3. 

Concluding Remarks 

The potential impacts ofGMD and HEMP are real; however, evaluating the effects of such 

events on existing and future power grid infrastructure requires concrete, scientifically-based 

analysis. Once the true impacts are known, including the potential unintended consequences of 

mitigation options, cost effective mitigation and/or recovery options can be developed and 

employed. 

The recent E3 assessment of the US bulk-power transformer fleet is merely a first step in a series 

of studies aimed at informing the electric utility industry of the potential impacts of HEMP on 

the bulk-power system. Although the results of this assessment indicate that E3 from a single 

high-altitude detonation would have marginal effect on bulk-power transformers, the results 

should not be interpreted as indicating that HEMP will not affect bulk-power system reliability. 

More research is needed to determine the impacts of E I on bulk-power system assets, and more 

importantly, the ability to accurately capture, through modeling and analysis, the synergistic 

effects ofEI, E2 and E3 is needed to assess the true impact of HEMP on the grid and develop 

cost-effective mitigation options. 

EPRI is committed to developing science-based solutions to these difficult problems, and offers 

technical leadership and support to the electricity sector, public policymakers, and other 

stakeholders to enable safe, reliable, affordable, and environmentally responsible electricity to 

the people of the United States. 

Page 8 of8 
49 

The CHAIRMAN. Thank you, Mr. Manning. 

Mr. Wailes, welcome. 

STATEMENT OF KEVIN WAILES, CHIEF EXECUTIVE OFFICER, 

LINCOLN ELECTRIC SYSTEM, AND MEMBER OF THE BOARD 

OF DIRECTORS, AMERICAN PUBLIC POWER ASSOCIATION 

Mr. WAILES. Chairman Murkowski, Ranking Member Cantwell, 

members of the Committee, thank you for giving me the opportunity to testify today. 

My name is Kevin Wailes. I’m the CEO of the Lincoln Electric 

System (LES) in Lincoln, Nebraska. I’m testifying on behalf of the 

American Public Power Association (APPA) on whose Board of Directors I serve. APPA is the voice for not-for-profit, communityowned utilities that serve 49 million people nationwide. 

I also serve as the Co-Chair of the Electric Subsector Coordinating Council which is made up of 30 utility and trade association 

CEOs and serves as the electric sector’s principle liaison with the 

Federal Government on policy level security issues. 

The electric sector takes very seriously the threat of electromagnetic pulse, or EMP, events and certainly, if you consider reliability, it’s what we do. That’s the primary objective for electric 

utilities in the first place. 

Chairman LaFleur provided a good description of the various 

types of EMP events. I want to emphasize, consistent with Senator 

Murkowski’s, Chair Murkowski’s, opening comments, that in effect 

a HEMP attack is an event that would be an act of war or terrorism, and in fact, is the responsibility of the Federal Government 

to prevent, as a matter of national security. But that doesn’t mean 

that we don’t take it very serious in trying to develop how we 

might mitigate that. 

The technical impact of a HEMP event on the electric infrastructure is uncertain. Though through a collaborative effort, as mentioned by Rob, with the Electric Power Research Institute and the 

Federal Government were conducting research to gain more information to be able to provide that mitigation. 

Some proposed the electric industry should install a particular 

protected device or fully gold-plate the entire grid so that it could 

survive a HEMP event. However, there’s really no consensus on 

what measures should be taken at this point. The potential unintended effects of that type of protection on the grid or how successful the efforts would be if we, in fact, tried to do that at this time. 

Cost is a significant factor. As a community-owned, not-for-profit 

utility, all additional costs borne by LES, for example, would have 

to be passed directly on to our customers. 

Assuming EMP blocking devices could be installed to protect the 

entire grid, power supply would still likely be disrupted by a 

HEMP event due to the collateral impacts on other critical infrastructures, as mentioned by Ms. Durkovich, the utilities rely on to 

provide services. 

EMP are one of many threats the electric sector must confront, 

as other witnesses identified, including severe weather events, geomagnetic disturbances, cyber and physical attacks. Given this 

broad threat landscape, our industry understands that we cannot 
50 

protect all assets from all threats and instead we must manage 

that risk. 

To do this, the electric sector follows a multilayered risk management approach to grid protection. A HEMP event is a high-impact, 

low-probability threat. We take EMP event threats seriously, but 

we must consider them within the context, a broader context of all 

threats. A cyberattack aimed at disrupting electric service would be 

a relatively cheaper and easier weapon to deploy and finding the 

needed nuclear materials and delivery vehicle to deploy that type 

of weapon. So clearly, we must place more effort on mitigating the 

highest and most profitable risk, probable risk. 

Given industry cannot protect the electric grid from all potential 

threats, we focus on all hazard recovery, that is, regardless of the 

cause of damage to the electric system, preparations to ensure mitigation, response and restoration are substantially the same. Grid 

operators must prioritize critical asset protection, engineer redundancy on to the system and stockpile spare equipment and as also 

mentioned, there are several programs that are ongoing with respect to enhance that capability given these new threats. 

In conclusion, electric utilities are working on multiple fronts to 

increase the scientific understanding of the potential impacts of 

EMP. As policymakers, there are several ways that you all can support that effort. 

First, the EMP Commission should be directed to work with owners and operators of critical infrastructure, EPRI, the North American Electric Reliability Corporation, and help assist the Electric 

Subsector Coordinating Council (ESCC), I’m sorry, and assess the 

vulnerability to the electric grid to EMPs. Collaboration between 

experts on EMP and experts in the utility industry will end up 

with the best product. 

Second, we need to ensure that the classified reports and research produced by both DoD and DOE are available and that can 

accurately reflect the threat we’re trying to evaluate so we can 

come up with the best solution. 

Finally, this is an extremely complex issue that cannot be solved 

with a one-size-fits-all solution, as previously identified. Prescriptive legislative directives could have unintended consequences and 

saddle ratepayers with increased cost with no associated value. 

Similarly, protecting the current successful standards in process 

put into place by the Energy Policy Act of 2005 is critical. This 

structure produces standards based upon expert input and necessity when it comes to vast and complex bulk electric system. 

Thank you for the opportunity to testify, and I look forward to 

answering any questions as part of the panel. 

[The prepared statement of Mr. Wailes follows:] 
51 

Testimony of 

KEVIN WAILES 

Chief Executive Officer, Lincoln Electric System 

On Behalf of the American Public Power Association 

Submitted to the 

SENATE ENERGY & NATURAL RESOURCES COMMITTEE 

For the May 4, 2017, Hearing 

"To Examine the Threat Posed by Electromagnetic Pulse and Policy Options to Protect 

Energy Infrastructure" 

Chairman Murkowski, Ranking Member Cantwell, and members of the Committee, thank you 

for inviting me to testify at the hearing today, "To examine the threat posed by electromagnetic 

pulse and policy options to protect energy infrastructure and to improve capabilities for adequate 

system restoration.'' 

My name is Kevin Wailes. I am the Chief Executive Officer at Lincoln Electric System (LES), 

headqumiered in Lincoln, Nebraska. LES provides electricity to approximately 135,000 

residential, commercial and industrial customers in Lincoln and the surrounding communities. 

Today, I am testifying on behalf of the American Public Power Association (APPA), on whose 

board of directors I serve. APPA is the voice of not-for-profit, community-owned utilities that 

serve 49 million people in 2,000 towns and cities nationwide. 

I also serve as a co-chair of the Electricity Subsector Coordinating Council (ESCC), a 

public/private partnership as outlined in the National Infrastructure Protection Plan (NIPP) for 

critical infrastructure owners and operators, which serves as the electricity sector's principal 

entity with the government on policy-level security issues. The ESCC is composed of30 utility 

and trade association CEOs, representing a cross-section of the electricity industry. It engages 

regularly with its federal government counterparts, including senior Administration officials 

from the White House, Department of Energy (DOE), Department of Homeland Security (DHS), 

the Federal Energy Regulatory Commission (FERC), the Federal Bureau oflnvestigation (FBI), 

and others as needed. 

Introduction 

Protecting the nation's electric power grid and ensuring a reliable and affbrdable supply of 

energy arc of utmost importance to APPA, its utility members, and the electric power industry. 

The power grid is a complex, interconnected network of generation, transmission, distribution, 

control, and communication technologies that can be impacted by a range of threats-from 

natural events like hurricanes, earthquakes, and geomagnetic disturbances (GMDs) caused by 
52 

solar flares, to malicious events such as cyber, physical, and electromagnetic pulse (EMP) 

attacks. Given this broad threat landscape, our industry understands that we cannot protect all 

assets completely from all threats, and instead must manage risk. To do this, the electric sector 

follows a multi-layered risk management approach to grid protection. The key to this strategy 

involves setting priorities to protect the most critical power grid components against the most 

likely threats. By framing risk as a function of likelihood and consequence, we can allocate 

resources more effectively. 

Electromagnetic Pnlses (EMPs) 

The threat we are here to discuss today are electromagnetic pulses or "EMPs." An EMP is a blast 

of electromagnetic energy that can potentially disrupt or destroy electronic devices within an 

affected area. Manmade EMPs are produced by nuclear weapons or other devices designed to 

create intentional electromagnetic interference. The electricity sector is not the only sector that 

would be impacted by an EMP··-any activity that relies upon devices containing integrated 

circuitry, such as industrial process control systems, hospital equipment, transportation, and 

telecommunication systems- may be a!Tected by an EMP attack. As such, the responsibility for 

protecting the United States from a national-level event like an EMP attack is that of the 

country's defense intelligence and military services, not individual critical infrastructure 

providers. 

There are two types ofEMP events of primary concern to the electric industry. The first is a 

"high-altitude electromagnetic pulse" ("HEMP'') caused by the detonation of a nuclear weapon 

in the atmosphere. A HEMP attack would have a potentially catastrophic impact on society; it is 

what the industry terms a "high impact, low probability" threat. An attack of this magnitude 

would be an act of war or terrorism, and thus the federal government has primary responsibility 

for preventing high altitude EMPs as a matter of national security. 

The second type of EMP results fi·om the use of a smaller directed energy weapon against a 

single facility or piece of equipment. Mitigation strategies for this type ofEMP threat include 

physical protection measures, including limiting proximity and controlling access, while also 

relying on system redundancy. To cause significant damage to the electricity grid, dozens of 

directed energy weapons would need to be built, deployed, and detonated in a coordinated attack 

without being detected or stopped by law enforcement. 

Protecting Infrastructure 

How exactly an EMP event would impact electrical infrastructure remains uncertain and is the 

subject of ongoing analysis. A recent study published hy Schweitzer Engineering labs concludes, 

by testing and analysis, that commercially-available intelligent electronic devices designed to 

meet lEC (International Electrotechnical Commission) requirements are resilient to HighAltitude Electromagnetic Pulse (HEMP) events. The Schweitzer study also concludes that 

existing IEEE (Institute of Electrical and Electronics Engineers) substation design standards are 

2 
53 

sufficient to protect intelligent electronic devices from HEMP. 1 Unfortunately, the Schweitzer 

report was prepared based on public-source EMP waveform data; access to classitied 

information on EMP waveforms would better inform the study and allow industry to better 

prepare for cost-effective mitigation. 

Some propose that to address EMP events, the electric industry install their particular ''protective 

device" or fully "gold plate" the entire grid so that it could, theoretically, at least partially survive 

a high altitude nuclear event. However, there is no consensus on precisely what measures should 

be taken, the unintended effects they might have on the system, how much such an effort would 

cost, or how successful such efforts would be in actually limiting impacts to the bulk power 

system. For example, due to non-uniform designs and complexity, substation solutions (e.g., 

Faraday cages) would have to be individually customized, which would not come at a 

standardized rate. Additionally, there are concerns that installing ·'protective devices" in some 

areas of the bulk power system could unintentionally cause problems in other areas. Further 

research and testing of these devices is needed. 

Even assuming that every conceivable blocking device were installed to protect every inch of the 

electric grid and caused no problems, power supplies still would likely be subject to disruption 

from other collateral impacts due to a HEMP event. That is because other critical infrastructures 

that uti! ities rely upon to function-such as transportation systems for generation fuel, water 

systems for cooling, and telecommunications for operations-may also be adversely impacted. 

To better understand the potential impact ofEMP and effective mitigation techniques, the 

Electric Power Research Institute (EPRI), an independent research organization tunded by 

industry, has embarked on an ambitious, three-year research project. This project is in 

partnership with government entities to determine the specific nature of the HEMP threat, based 

on objective evidence, and to develop cost-effective strategies for mitigation. On February 21, 

2017, EPRI released the tirst in a series of assessments on how an EMP caused by the detonation 

of a high altitude nuclear weapon above the U.S. would affect the electric grid 2 This first study 

found that a small number of large power transformers (3 to 14 of 37,000 analyzed) would be at 

risk for thermal damage. Its tindings represent only one piece of a complex puzzle. More work 

is needed to tully investigate other potential impacts to the entire bulk-power system and will be 

pursued in subsequent phases of the project. 

Enhancing Capability for Adequate System Restoration 

Government-industry coordination on national security issues such as EMPs is critical to 

preparing an effective response to these national security threats. One such effort is the Electric 

Subsector Coordinating Council (ESCC), which serves as the principal liaison between the 

federal government and the electric power industry. The ESCC is a forum for electric sector 

CEOs and top-level government executives from DOE, DHS, the FBI, and other organizations to 

engage on current and emerging threats like EMP that would have cross-sector and national 

1 Understanding Design. Installation, and Testing Methods That Promote Substation JED Resiliency for HighAltitude Electromagnetic Pulse Events, Tim Minteer, Travis Mooney. Sharla Artz, and David E. Whitehead, 

Schweitzer Engineering Laboratories, Inc., February 2017. 

))!JJl2~:~'~~~"J,Q)J11,2[~1~~-I~~!Jl~c!JIII'\~':l~~~ci~J~~~~!l. 

3 
54 

security implications. The ESCC works across the electric power industry, with the government 

and other interdependent critical infrastructure sectors to improve planning for, and response to, 

major incidents. The ESCC formed a R&D task force to address several issues including EMP 

and is supporting EPRI's EMP Project. 

Regardless of the cause of damage to the electric system, preparations to ensure mitigation, 

response and restoration are the same: grid operators prioritize risk to enhance protection around 

critical assets, engineer redundancy to avoid single points of failure, stockpile spare equipment 

for hard-to-replace components, and develop other contingencies to minimize impacts. The 

ESCC is involved in all aspects of these preparations. 

• Exercises: Electric utilities plan and regularly exercise for a variety of emergency 

situations that could impact our ability to provide electricity. The industry participates in 

many incident response exercises, including five national-level exercises since November 

2015. One such exercise, GridEx Ill, involved more than 360 organizations and 4,400 

participants from industry, government agencies, and partners in Canada and Mexico. 

Managed by the North American Energy Reliability Council (NERC) and the Electricity 

Information and Analysis Center (E-ISAC), Grid EX Ill also included an executive 

tabletop exercise where 32 electric sector executives and senior U.S. government officials 

worked through incident response protocols to address widespread outages. 3 Grid Ex 

events are conducted every two years; Grid Ex IV is planned for November 2017. 

• Mutual Assistance Programs: The three segments of the electric utility industrypublic power, investor-owned, and rural electric cooperatives-have long had in place 

mutual aid response networks to share employees and resources to restore power after 

emergencies. The years of experience industry has had in deploying these resources is a 

valuable tool. In fact, the ESCC has led efforts to create a Cyber Mutual Assistance 

(CMA) program that will allow utilities to share critical personnel and equipment in the 

event of cyber-related emergencies. To date, I 00 utilities are participants, covering about 

80 percent of the country's electricity customers-or 118 million. 

• Spare Equipment Programs: Electric companies regularly share transformers and other 

equipment through long existing bi- and multi-lateral sharing arrangements and 

agreements. The industry is expanding equipment sharing programs-like the Spare 

Transformer Equipment Program (STEP), SpareConnect, and the newly formed Grid 

Assurance program-to improve grid resiliency. 

• Transformer Transportation Emergency Support Guide: The ESCC, in coordination 

with other critical infrastructure sectors and the government, has developed a 

Transformer Transportation Emergency Support Guide to expedite the deployment of 

large spare equipment, such as transformers, quickly over rail, roadways, and waterways 

in an emergency. 

3 NERC is the electric reliability organization (ERO) for North America, subject to oversight by the Federal Energy 

Regulatory Commission (fER C); it develops and enforces reliability standards t(w the bulk power system. TheEISAC serves as the primary security communications channel for the electricity sector. 

4 
55 

• Supplemental Operating Strategies: Following GridEx Ill and the cyber incident 

affecting Ukrainian distribution electric companies, the industry focused on electric grid 

operations under sub-optimal circumstances. The ESCC has asked grid experts to explore 

"extraordinary measures" that can be anticipated, planned for, and practiced so they are 

not contemplated for the first time during an incident that disables significant technology 

used to operate the grid. These "extraordinary measures'' include, but are not limited to, 

operating systems in "manual" configuration where systems are not allowed to 

automatically re-energize, engaging in planned separations or "islanding" of portions of 

the grid to avoid cascading outages, leveraging secondary and tertiary back-up systems, 

or operating in other degraded states. 

• Research & Development: The ESCC R&D strategic committee is overseeing the 

industry's collaboration efforts with the government, including the national labs, on 

resilience and infrastructure investments for grid security R&D. In July 2016, DOE and 

EPRI announced the Joint Electromagnetic Pulse Resilience Strategy to " ... enhance 

coordination ... and to guide future efforts to help meet the growing demands for EMP 

guidance."4 DOE and EPRI committed to developing separate, but coordinated, Action 

Plans to implement the goals outlined in the Joint Strategy; DOE released its Action Plan 

in January 2017. 5 

Conclusion and Rccommeudations 

As I hope I have conveyed, the electric utility industry takes the threat of EMPs seriously and we 

are working on multiple fronts to increase the scientific understanding of the potential impacts, 

including mitigation and response options. As policymakers, there are several ways in which you 

can support our efforts. First, we recommend that the reconstituted EMP Commission be directed 

to work with owners and operators of critical infrastructure, EPRI, ESCC, NERC, and the EISAC as the Commission executes its mission to assess the vulnerability of the electric grid to 

EMPs and to develop recommended policy actions. Combining the unique backgrounds of the 

EMP Commission with the knowledge of experts in grid engineering and operations would 

produce a more meaningful and informed product. Allowing industry representatives with 

appropriate security clearances to access classified EMP reports produced by the Departments of 

Energy and Defense would also be immensely helpful. The more information we have on the 

potential threat, the better we can mount an effective response. Finally, I want to reiterate that 

this is an extremely complex issue that cannot be solved with a ·'one-size-fits-all" solution. 

Prescriptive legislative directives could have unintended consequences and saddle ratepayers 

with increased costs for which they receive little or no additional benefits. Similarly, protecting 

the current successful NERC/FERC standards-setting process that this committee developed in 

the Energy Policy Act of2005 is critical. This structure produces standards based upon expert 

input, a necessity when it comes to the vast and complex bulk electric system. 

Thank you for the opportunity to testify. I look forward to answering any questions you may 

have. 

5 
56 

Supplemental Document to the Testimony of 

KEVIN WAILES 

Chief Executive Officer, Lincoln Electric System 

On Behalf of the American Public Power Association 

Submitted to the 

SENATE ENERGY & NATURAL RESOURCES COMMITTEE 

For the May 4, 2017, Hearing 

"To Examine the Threat Posed by Electromagnetic Pulse and Policy Options to Protect 

Energy Infrastructure" 

Exercises 

The electric sector plans and regularly exercises for a variety of emergency situations that could 

impact their ability to provide electricity. The industry participates in many incident response 

exercises, including five national-level exercises since November 2015. 

I. GridEx III (lVERC, November 2015) gathered more than 360 organizations and 

4,400 participants from industry, government agencies, and partners in Canada and 

Mexico. Grid EX Ill also included an executive tabletop exercise where 32 electric 

sector executives and senior U.S. government officials worked through incident 

response protocols to address widespread outages. 

II. Clear Path IV (DOE, Apri/2016) convened 200 participants from the oil and gas and 

electric power industries and federal and state officials to test response and restoration 

protocols to a catastrophic simulated earthquake and tsunami in the Pacific 

Northwest. 

111. Cascadia Rising (FEMA, June 2016) was a three-day exercise that tested first 

responders and government emergency personnel responders and government 

emergency personnel responses in the immediate aftermath of a significant 

earthquake. 

IV. Cyber Guard (DOD!NSA. June 2016) was a two-week exercise that tested the 

response capabilities of I ,000 energy, IT, transportation, and government experts to a 

mf\ior cyber-attack. 

V. .Joint Financial Services- Electric Sector Cyber Exercise (Treasury, August 2016) 

examined incident response capabilities and interdependencies between the two 

sectors. 

Spare Equipment Programs 

Electric companies regularly share transformers and other equipment to improve grid resilience 

from a range of threats. There are multiple spare transformer initiatives: 

6 
57 

l. Spare Transformer Equipment Program (STEP) - In 2006, federal energy 

regulators approved the Spare Transformer Equipment Program (STEP), an electric 

industry program that strengthens the sector's ability to restore the nation's 

transmission system more quickly in the event of a terrorist attack. STEP represents a 

coordinated approach to increasing the electric power industry's inventory of spare 

transformers and streamlining the process of transferring those transformers to 

aftected utilities in the event of a transmission outage caused by a terrorist attack. 

Under the program, each participating electric utility is required to maintain and, if 

necessary, acquire a specific number of transformers. STEP requires each 

participating utility to sell its spare transformers to any other participating utility that 

suners a "triggering event," defined as an act of terrorism that destroys or disables 

one or more substations and results in the declared state of emergency by the 

President of the United States. 

Any investor-owned, government-owned, or rural electric cooperative utility in the 

United States or Canada may participate in the program. Currently over 50 utilities 

are members. 

II. SpareConnect- The SpareConnect program provides an additional mechanism for 

Bulk Power System (BPS) asset owners and operators to network with other 

SpareConnect participants concerning the possible sharing of transmission and 

generation step-up (GSU) transformers and related equipment, including bushings, 

fans and auxiliary components. SpareConnect establishes a confidential, unified 

platform for the entire electric industry to communicate equipment needs in the event 

of an emergency or other non-routine failure. 

SpareConnect complements existing programs, such as the Spare Transformer 

Equipment Program (STEP) and voluntary mutual assistance programs, by 

establishing an additional, trusted network of participants who are uniquely capable 

of providing assistance concerning equipment availability and technical 

resources. SpareConnect does not create or manage a central database of spare 

equipment. Instead, SpareConnect provides decentralized access to points of contact 

at power companies so that, in the event of an emergency, SpareConnect participants 

are able to connect quickly with other participants in affected voltage 

classes. SpareConnect does not impose any obligation on participants to provide any 

information or to make any particular piece of equipment available. Once connected, 

those SpareConnect participants who are interested in providing additional 

information or sharing equipment work directly and privately with each other on the 

specific terms and conditions of any potential equipment sale or other transaction. 

As of March 27, 2017, SpareConnect has 129 member utilities. Seven of the 

municipal utility members are joint action agencies that participate on behalf of 

themselves and their 176 municipally-owned utilities. Generation & Transmission 

(G&T) cooperatives within SpareConnect participate on behalf of 180 distribution 

7 
58 

cooperative systems. 

Ill. Grid Assurance- Launched in 2016 by six large electric utility companies, Grid 

Assurance is an independent company created to enhance grid resiliency by giving 

electric transmission owners taster access to long-lead time critical equipment 

necessary to recover from catastrophic events that could impact the nation's electric 

grid. More information is available at blh't'::i\_~1\.UI'ilillj_sura]l<;f.comfl.'lndustnDrivcn 

8 
59 

The CHAIRMAN. Thank you, Mr. Wailes. Thank you, all, for your 

comments here this morning. 

Let me start with just a broad question to you all. Is it fair to 

say that you would all agree that an EMP attack is, in the first 

instance, a threat to national defense? Do we agree that is what 

we are dealing with? 

Ms. LAFLEUR. Yes, Senator. 

The CHAIRMAN. Chairman? 

Mr. GINGRICH. Yes. 

Ambassador COOPER. Yes. 

Ms. DURKOVICH. Yes. 

Mr. MANNING. Yes. 

Mr. WAILES. Yes. 

The CHAIRMAN. Okay, we have agreement here. 

Now the question is what we do with this? 

I do appreciate the various suggestions that have been presented 

here and how we can work to protect, how we can become more resilient. 

Speaker Gingrich, you mentioned the prospects for a broad infrastructure package and what we might be able to do in the context 

of national security. It begs the question, though, and you have indicated, Mr. Wailes and I think others have said, this is a tough 

order. There is really not a one-size-fits-all here. But is there commercialized technology the industry could use to protect against 

EMP attacks, and if not, what are the barriers to deploying the 

technology? 

Cost has been mentioned, most specifically, but how prepared are 

we, if we were to get this infrastructure package? Do we have 

something that we could actually lay down there that could be constructive? I will let anybody jump on this one. 

Mr. GINGRICH. Let me, if I can for a second, I want to make, sort 

of, a deeper point about where we’re at. 

We’ve done an extraordinarily elegant job operating off of a paradigm of efficiency to create an electric system for North America. 

It’s really extraordinary. 

You now have to shift from that model to a model that says you 

want resistance, redundancy and resilience. Then you have to create, first of all, just the model and that’s why I said—part one of 

this is, at least in part, the Department of Energy and the Department of Homeland Security modeling what would that system look 

like. 

It’s not a situation where you get a choice, where you get to say, 

you know, I’m going to take the risk of being destroyed by cyber 

because I’m really going to focus on EMP. You’ve got to look at all 

the major threats, figure out what the notable points of defense are 

against all of them and then design a policy to fit that. And this 

will be the more expensive system. Then you’ve got to figure out 

what part of that more expensive system is a national defense requirement in which case it ought to be borne directly by the government. What part can you legitimately say we can find offsetting 

savings, as I mentioned earlier, just in cutting the red tape and the 

time, value and money you could save an enormous amount of resources that the industry would, I think, be happy to swap and put 

that money back into a more resilient system. 
60 

But I think you’ve also got to ask the question, I think there 

ought to be real urgency and cutting through all of this and setting 

very tight deadlines for implementation because I think we’ve 

known since 2004 that the Russians have given the North Koreans 

this capability. We’ve known since the 1990s that the Chinese have 

been developing this capability. And the capacity for a North Korean satellite to have an EMP weapon is a very real danger in real 

time, today. 

So, I think we have to have, well, almost, a wartime urgency of 

setting this up, offsetting the cost and to your point, in some areas 

we don’t currently have a solution and there are obvious significant 

research projects, DARPA and others, to be engaged in figuring out 

the specific breakthrough points, how are we going to solve these 

things? Because if we don’t solve them there’s a genuine catastrophe that could happen that would be of horrendous consequence. 

The CHAIRMAN. Chairman LaFleur, and as you answer this I 

want to know whether you believe FERC has sufficient regulatory 

authority to address these EMP concerns and really, where we are 

with that, as you respond to this other point. 

Ms. LAFLEUR. Thank you, Senator. I’ll take the questions in 

turn. 

So, your first question was is there technology available to protect against EMP? The answer is there is some technology available to protect some equipment against EMP. For example, the 

military sheaths some of its intelligence equipment in metal in 

some of its intelligence centers. So there is some technology available. 

The difficulty on the electric grid is knowing where you would deploy the technology to best protect the grid in an effective way because when we are going to mandate a standard for thousands of 

transmission owners, we want to make sure it’s going to work and 

it’s going to do the job that it’s intended to do. 

Speaker Gingrich has referred to the study of the nine substations. I know that’s a controversial study. I’ve testified about it 

here before. That was a study that was looking at simultaneous 

physical attacks on transformers and cascading of transformers, 

whether its results are right or not, that’s what it was talking 

about. 

If I were to go to protect the grid from EMP I’m not sure, I’m 

quite certain those nine substations, wherever they are, are not 

where I would go. I’d probably go to the control centers first because you can’t even turn a substation on and off without the communications from a control center. Those are ubiquitous in every 

territory. 

So we need to figure out, for this risk, which is different from a 

storm or a, even different from the risk we’re protecting against 

with the physical security standard which was for the substations, 

where is the best place to go? That’s the work Mr. Manning and 

others are doing. 

To your second question, we do not have the authority, as you 

know, under the law to write a requirement ourselves and say everyone, you have to do this. We have been given a complex statute 

under which we oversee NERC in a voting protocol, and they file 

a standard. We can reject it if it’s not strong enough and make 
61 

them change it. We can direct them to do a standard but it’s a— 

that’s the way the structure works. 

Within that authority, we could certainly direct NERC and the 

industry to do a standard if we believed we knew what they should 

do. And I have every confidence they would respond as they have 

with GMD, physical security, supply chain management and other 

things where they opposed initially but when we directed it, they 

did a standard. 

The CHAIRMAN. I appreciate that, thank you. 

Senator Franken. 

Senator FRANKEN. Thank you, Madam Chair. 

In reading through the testimony provided for today’s hearing, it 

became clear that some of the witnesses are quite alarmed about 

the threat of an EMP attack and the potential societal impacts and 

others are clearly more circumspect. 

Chairman LaFleur, could you comment on where we should direct the efforts and resources we devote to enhancing grid security? 

What should our priorities be? Where would you place physical attacks which is on Metcalf, cyberattacks, EMPs, GMDs and other 

threats on a triage list? 

Ms. LAFLEUR. Well, it’s a difficult question because we’re comparing attacks that are very numerous and kind of low barriers to 

entry, like cybersecurity when you don’t have to be a nation-state. 

A lot of people can do it too, as several have said, high impact, low 

probability. 

I mean, I think that, first of all, we have to have a strategy for 

all attacks. I think right now I would probably put cybersecurity 

as number one, but that doesn’t mean we don’t need to protect our 

substations from physical attacks or that we don’t need to protect 

against solar storms, which we are protecting against, and work on 

the EMP issue and figure out how to protect that. 

I think taking a step back, to me, where we should be going, the 

real solution, is to build resilience into the grid, to build the grid 

in a way that we have more redundancy, that we can island, that 

we have more inventories as we’re working on because that works 

against all risks. 

I think resilience, which is increasingly where our efforts are 

going, is the strategy that works, whether it’s a hurricane or an 

earthquake or something else. 

Senator FRANKEN. So when you are talking about island mode, 

making sure there are just, sort of, circuit breakers, the opposite 

of circuit breakers, just so that if one goes down, not everything 

goes down. 

Ms. LAFLEUR. Well, you can’t obviously, you can’t have a backup 

for everything, but we have standards, for example, that critical 

control centers have to have backups, secondary supply lines and 

so forth. 

In the geomagnetic disturbance standard, the first part of the 

standard we put out was an operating procedure standard. When 

we hear from NOAA that there’s a solar storm coming within half 

an hour, there’s an immediate transmission to every control center 

in the United States. And they have to know, okay, which—how do 

I go into safe mode? What do I do in the time that I have? 
62 

Now, we might have no warning of a bomb, but for GMD, that’s 

precisely what they’re working on. 

Senator FRANKEN. Okay. 

Mr. Wailes and Mr. Manning, can you give the perspective of 

those who work in the industry and daily face of the near end, 

long-term threats to the security reliability and resilience of our 

electrical system? Which threats do you believe we should 

prioritize? 

Mr. WAILES. I actually concur with Chairman LaFleur. And we’re 

looking at today’s environment, we see the cybersecurity threat as 

a much higher threat. And we have a significant investment and 

a lot of work going toward that, as we speak. 

But I would like to address, kind of, the perception that we don’t 

have a lot of redundancy built into the system now. That is actually part of the core of reliability, again, is electric utility, reliability and low cost are our primary objectives, but reliability is the 

primary one. 

So whether you’re talking about, you know, transformer capacity 

to serve substations or you’re talking about circuits, all of that is 

looking at that reliability is built into your generation fleet. When 

you look at how you plan against generation and reserves for different types of events, that is something we do routinely, but there 

are different things that we’re looking at with current day threats 

that hadn’t existed previously and how we’re going to deal with 

those. 

The research that EPRI is doing, the work we do, for example, 

with the ESCC. I think one of the striking things, many of you may 

have heard about the GridEx exercises which are really significant 

exercises that are developed between the Electric Subsector Coordinating Council, NERC and the ISAC, which is the electric sector 

Information Sharing and Analysis Center. They take a year and a 

half to develop these exercises, and they look at very catastrophic 

types of events. 

Some of the learning out of that that we get between the Federal 

Government partners and the industry is more of an understanding 

of how much redundancy is in the system and some of the issues 

that we have to actually share information about how are we going 

to be more resilient and how are we going to respond. All of those 

things are an ongoing approach for us, on a continual basis. 

The difference is those threats are changing. And that’s one of 

the things we found, even with the EMP threat. And we all 

thought there was a cold war we didn’t have to worry about that 

anymore, nor did we have, as pointed out in the opening comments, 

the kind of sensitive—we had analog devices. We didn’t have devices that were as sensitive as we do today. 

So as those threats have evolved, we have to get more understanding about how they impact what we do. And we also know 

that the easier threat now to us is a cybersecurity threat and the 

physical security threats. 

Senator FRANKEN. I know I am way over. 

Mr. Manning, would you respond to that briefly? 

Mr. MANNING. Yes, Senator. 

The first thing that came to my mind is that we like the information to make that decision, that we react, based off of our experi-
63 

ences. So if we have a high probability of cyberattack, then we immediately respond to cyber issues. 

We lack sufficient information to understanding exactly what the 

probability is and what the severity is of attacks like EMP. That 

information is becoming clearer and we’re beginning to understand 

that. And once we have adequate information about EMP, then we 

can balance that sufficiently, I believe, with threats like cybersecurity where we have quite a bit of information. 

Actually, I think we talked about it earlier that risk is really 

about managing probability and severity and we have to look at 

both of those things. Well, in the industry we can do absolutely 

nothing about probability of an EMP attack, so we’re focusing all 

of our efforts on severity. And if we can reduce the consequences 

of an EMP attack to the point where the probability no longer matters, then I think, we’ve actually made progress. 

Senator FRANKEN. I just want to make one last comment which 

is really a question. 

Is this an argument for more distributed energy, more solar panels on rooftops, more island mode energy? 

The CHAIRMAN. Let’s go to Senator Cassidy. 

We will leave that question hanging. 

Senator FRANKEN. The hanging question. 

Senator CASSIDY. I will start with Ms. LaFleur. 

Madam Chair, the Hawaii outage after the atmospheric nuclear 

test, was that due to an E1, E2 or E3? 

Ms. LAFLEUR. I believe it was due to E1. I believe it was communications equipment that was destroyed. 

Senator CASSIDY. Mr. Manning, you all have looked at, you said, 

E3 and found it to be less consequential than a severe GMP. What 

I read in my notes is that E2s are more like lightning so it seems 

like E1 is, you said, not yet tested. 

Now, again, just coming up to speed, what you already know. So 

that is communications. Would that also threaten the grid or no, 

would this be specific—more likely to affect communications? 

Mr. MANNING. If I can circle back on that question. 

Our findings on E3 are also partial. There is still additional work 

to be done on E3. We specifically investigated impact of bulk power 

transformers. We looked at the 37,000 or so bulk power transformers in the continental U.S. grid. As a result of only the E3 

pulse, what we discovered is that the damage to those would likely 

be less severe than originally thought. 

It has—— 

Senator CASSIDY. I only have three minutes. 

You have got to hustle, man. I am sorry. 

[Laughter.] 

Mr. MANNING. It has a correlation to GMD, but it’s not directly 

related to GMD; however, you can’t stand that up on its own. It 

must be associated with the plethora of energy waves from a nuclear attack. So you must consider E1, E2, E3, all together, and 

we’ve only begun to consider that. 

Senator CASSIDY. I got ya. So, whatever my questions about E1, 

it has to be considered within the context of E1, E2, E3, 

conglomerately. 
64 

Mr. MANNING. Absolutely, unless it’s a handheld device which is 

only an E1 pulse. 

Senator CASSIDY. Madam Chair, speaking of a geomagnetic, if I 

am getting all that right, what I quickly read about the Carrington 

event is that there was a 17.6-hour lead-in. They saw the flare, but 

the physical effect was not seen. And I read that in some places 

they actually unhooked their telegraph from the power source. 

Typically you would have a several day lead-in. We see the flare. 

That said, is it possible if there is such a flare from the sun that 

everybody could go home and unplug their computers, put in their 

surge protectors and otherwise protect their equipment? 

Ms. LAFLEUR. Well first of all, much more so than in 1859, our 

weather satellites give us good information, usually you know several days ahead something is coming, but the details of where it’s 

going to go is more like in minutes or hours than days. 

That’s the purpose of the operating procedure standard that is 

communicated to the control centers so they can protect the high 

voltage transformers and so forth, which take a lot longer to replace which are the most impactful equipment on the system in 

many ways. 

In theory, you could go protect your own equipment, but the 

solar storm doesn’t have the same effect on communications. So, I 

don’t think there’s a lot of concern that it would destroy home electronics. 

Senator CASSIDY. I guess I was using that as, kind of, a metaphor. 

Ms. LAFLEUR. Yes. Electric companies could do things like that. 

Senator CASSIDY. They could. So we do have some advance notice 

and we could take some protection? 

Ms. LAFLEUR. That’s why that was the first standard we put in 

place because you don’t have to do equipment modifications. It’s actually just planning of what you would do. 

Even when I used to run a distribution company, even when we 

had hurricanes or snow storms coming, sometimes you configure 

your system in a different way to prepare because you know where 

your vulnerabilities are. It’s similar, but bigger scale. 

Senator CASSIDY. Now going back to the point that Senator 

Franken made that some of you were more sanguine and others 

less so. I read about a 1989 geomagnetic storm which only affected 

Quebec and maybe a few Australians over in Namibia, but as far 

as I know it didn’t affect Louisiana. That said, it tells me that even 

though we were about this being global at first, at times we have 

these geomagnetic storms and it is local. 

Ms. LAFLEUR. It depends on the size of the solar flare. One like 

a Carrington event is larger. Most of them are more regional. Our 

standard that’s now in effect requires specific mitigation depending 

on the latitude and the soil and so forth. 

Louisiana is a little closer to the equator. In general, the poles 

are—this is one—you have a lot of hurricane issues, but this particular problem closer to the poles is generally considered more exposed to solar radiation. 

Senator CASSIDY. So my kind of sense from everything, what 

you’re saying is that we really do have an understanding and some 

advance warning that someone said if we can prevent it, it’s a lot 
65 

better, that at least with that which might come from the sun, 

granted it could overwhelm and the Speaker mentioned that. 

Ms. LAFLEUR. Yes. 

Senator CASSIDY. But still we are somewhat prepared for that 

from the solar. 

Ms. LAFLEUR. Well, because we monitor all the time, some of the 

transformers have monitoring attached, they can get regular updates on what’s happening with the sun and how it affects them. 

Fortunately we don’t have a lot of experience monitoring explosives 

in the upper atmosphere. That’s not the kind of monitoring experience we want to get. So, you can’t develop the fact-based, experience-based information like with the sun. 

Senator CASSIDY. Got it. 

Thank you. I yield back. 

The CHAIRMAN. Thank you. 

Senator Wyden. 

Senator WYDEN. Thank you, Madam Chair and thanks to all of 

our witnesses. This is a very, very hectic day. The Speaker knows 

a little bit about what those are like up here. I just have a couple 

of questions. 

First, I want to note a point I am not sure has been made, and 

that is in the skinny budget the cuts that the Administration is 

looking at for agencies like NOAA and NASA is going to make it 

much tougher, much tougher, for the Congress on a bipartisan 

basis to deal with the important issues that we are talking about 

here today. 

I think there is a real role for government to play as it relates 

to improving the resiliency of the grid, and those are the questions 

that I want to touch on with all of you. I will start, Mr. Manning, 

with you and Ms. Durkovich. 

As you know, what we really are concerned about in our part of 

the world is the large earthquakes along the Cascadia Subduction 

Zone. This is a major, major issue for the people of the Pacific 

Northwest with respect to this whole issue of resiliency. 

Now my take, with respect to the science, and it picks up on a 

point where, I think, Senator Franken was trying to go, is 

microgrids and distributed energy resources. And here we are talking about rooftop solar. Energy storage can play a very real role in 

helping the grid quickly recover if you get hit by an event like this. 

So, for you, Mr. Manning, and you, Ms. Durkovich, could you just 

briefly walk the Committee through the role that these technologies could play in adding resiliency to the electric system when 

we are thinking about, in our part of the world, a physical threat 

like a Cascadia disaster? 

For you, Mr. Manning, and you, Ms. Durkovich. 

Mr. MANNING. So it’s an excellent question, thank you, Senator. 

There is no doubt that distributed energy that is grid connected 

introduces additional redundancy to the grid. As Kevin mentioned 

earlier, redundancy is a part of reliability. So the more redundancy 

we can add and couple into the grid, the greater potential we have 

for increasing reliability. 

But it’s not a failsafe. In the event of an earthquake, for example, distributed energy is probably an excellent solution to offer alternatives to centralized generation. In the event of an EMP, by 
66 

contrast, there’s nothing that specifically protects those distributed 

energy resources any better than the centralized energy resources. 

So in the event of an EMP, you’re likely to see the control systems 

for rooftop solar or for storage or for microgrids would also be impacted by that EMP. They would also be rendered ineffective unless they’re hardened specifically for that. However, for weather 

events, for other events, even potentially cyber events, they add 

value because they add redundancy. 

Senator WYDEN. Okay. 

Ms. Durkovich? 

Ms. DURKOVICH. Thank you. 

That’s really an excellent question. I think another example of 

how government and industry have come together to think about 

how we are going to address impacts to the grid from some of these 

lower probability, high impact events. In 2016, there was a major 

exercise called Cascadia Rising which focused on just this, the 

Cascadia Subduction Zone and the fact that, like a Carrington 

event, we are a little bit overdue for this scale of earthquake in the 

Pacific Northwest. 

I would agree that certainly distributed energy can help speed 

restoration to the communities, but this is, again, another type of 

incident where we really need whole of community effort when you 

think about the potential damage and consequences that we’re 

going to see in something like this. 

And so, it is important for us to continue to do the large-scale 

exercises that bring together our state and local’s industry and government to help us think about, alright, what are the impacts 

going to be to the grid? What are the impacts going to be to communications? To transportation? How are we going to get basic 

commodities into this area? How are we going to make sure first 

responders can get in and equally important the utility and the 

linesmen, to help get the systems up and running? 

So this is not an easy challenge, but it’s why we bring folks together to think through, alright, what are we dealing with and how 

are we going to speed recovery? 

Senator WYDEN. Very good. Thank you all. 

The CHAIRMAN. Thank you, Senator Wyden. 

Senator Risch. 

Senator RISCH. Thank you, Madam Chairman. Thank you for 

holding this hearing. 

We have heard a lot of criticism, or at least concern this morning, about the government’s response to the growing threat of grid 

security and to cybersecurity. In large part, I think, there is certainly criticism to be had and certainly a lot of concern to be had. 

Part of it, I think, has grown out of frustration that, I think, 

there isn’t a lot out there about what the government is doing. I 

sit on the Intelligence Committee, Senator King sits on the Intelligence Committee and Senator Wyden sits on the Intelligence 

Committee. I can tell you that these issues have not been ignored 

by the United States. Most of what we know about it, most of what 

we are doing about it, cannot be discussed in this setting. It is 

going to be a closed setting, only for people with the security clearance necessary. 
67 

So, in that regard, it isn’t quite as bad as what everybody is saying. But Speaker Gingrich, your deep insights into the consequences are greatly appreciated. We have been through these exercises and your statements are certainly not overstated. 

I would take issue though, as far as your recommendation, if we 

have an infrastructure bill coming. I can tell you based on what we 

know about where we are and what we are doing, I think that is 

appropriate at some point in time, but we are not ready yet. You saw what happened when they had this last $2 trillion, 

whatever it was, bill to stimulate. When you start throwing money 

at the wall a lot of it doesn’t stick, and the term ‘‘shovel ready’’ was 

used a lot. We are really not ready. We do not have shovel ready 

products yet. Certainly, we need more research and that could be 

included in that, but I would just be a little reluctant to start 

digging and laying stuff in the ground at this point. 

But there are things going on on this, and I think a lot of us on 

the Intel Committee are convinced that the next significant events 

in America are going to be a cyber event. That is where we have 

vulnerability. But certainly the grid is linked to that. And the bad 

guys, of course, Senator Franken had asked which was more, what 

is the most concerning right now? Well, we have to be able to walk 

and chew gum at the same time because, as we sit here today, 

there are different people working on different ways to attack us. 

And these are all included in that, whether it be North Korea trying to develop a weapon to drop on us or whether it be other state 

actors and non-state actors who are trying to get us through the 

grid and through the cybersecurity. 

Ms. LaFleur, thank you for the shout out today at our National 

Laboratory. Obviously, we are becoming, in Idaho, the go-to and 

the flagship on grid security. You saw the test bed that we have 

out there and the kinds of things that we are doing there on grid 

security, working with private industry. I think most Americans 

would be very pleased to see what is going on out there and the 

kinds of things that we are doing to try to mitigate them as we go 

into the future. 

In any event, we are going to continue to work on this. I think 

it is important. I really appreciated Ms. Durkovich and Mr. Wailes’ 

description of risk management because, you know, after you sit 

here for a while today, you realize the threats to America, how 

many there are and how diverse they are and the widespread 

places that they come from. 

There are a lot of people out there that just, for their own reasons, want to do us harm. And yes, we have to be able to walk and 

chew gum at the same time. Yes, we have to be able to address all 

those threats. But you have got to do it on a risk management 

basis because there isn’t enough money in the world to protect us 

100 percent, whether it be the grid or whether it be the cybersecurity or just a normal kinetic attack. 

There was frustration, I think, expressed for the Department of 

Defense. We work with the Department of Defense, the Intel community works with the Department of Defense all the time, and I 

think that criticism is probably pretty well taken. I say this with 

great love and respect for the Defense community, but they are 

much more focused on the classical kind of warfare and the clas-
68 

sical kind of defense that has always been and we have always 

challenged them to provide for America. 

These new things that are coming along, like cyber and grid and 

what have you, have not been in the wheelhouse. They are getting 

up to speed but so is the electrical industry and everything else. 

Probably one of the most telling things we hear in the Intel community is when we have these experts in on the grid and everything and I think this, kind of, put it in perspective for me. When 

you work on these problems and you try to predict what is going 

to happen and then try to design a defense to it, these people will 

tell you, when it comes to cybersecurity we are where the Wright 

Brothers were. We don’t know what we don’t know. And we keep 

learning things. 

A good example of that as Speaker Gingrich very rightly pointed 

out is the fact that all of this stuff is designed for efficiency. Well, 

when you design it for efficiency, you design in huge 

vulnerabilities. 

The Ukrainian attack taught us something. In fact, some legislation came out of that, and that is that the Ukrainian attack was 

not as bad as what it could have been because their system was 

not very efficient. It actually had to go through human beings. And 

when it got to these human beings, the human beings recognized 

what was going on and they were able to mitigate that. 

Senator King and I are co-authors of—— 

Senator KING. S. 79. 

Senator RISCH. S. 79. Thank you, Senator. 

We call it the back to the future bill where you actually back up 

and start to look at these efficiencies and see if there are some 

places where we can put in some of these kinds of things. 

Anyway, I have talked long enough. Again, this is an incredibly 

important hearing, incredibly important subject. Thank you for 

holding it, Madam Chair. 

The CHAIRMAN. We appreciate that input, Senator Risch. 

Senator King, now you can speak to your bill here. 

Senator KING. Thank you. 

First, I want to welcome Speaker Gingrich. It is always a pleasure to have your wisdom and insights. I still remember very well 

a day we spent in Maine when we were lonely voices talking about 

digital education back in about 2000, so I appreciate that. 

Mr. Manning, and I think this gets a little bit to where we have 

been focusing today, we were talking about distributed energy and 

you appropriately said that could be a part of the redundancy and 

defense. Unless they are hardened, you said. That is my question. 

Are there reasonably priced, hardening tools out there? In other 

words, could we build in to every house, as part of the electrical 

system, some kind of high test surge protector that would be a defense in this situation? And by the same token, a similar kind of 

device in the grid back at transmission points? 

Mr. MANNING. That’s a wonderful question. 

I think the answer to that is there could be. Today, it’s probably 

not, as we just heard, is not shovel ready. There are a lot of different components that need to be added together. But this will 

take a fundamental design change, in some respects, particularly 
69 

for home-based equipment. You’ll have to think about it differently 

and make just complete design changes—— 

Senator KING. Are the utilities thinking about this for their critical points? In other words, to me this is an insurance question. 

Mr. MANNING. Yes. 

Senator KING. How much is the insurance policy going to cost 

versus the risk? 

Mr. MANNING. And one of the things that we are doing with our 

report which will be out this summer is taking the military EMP 

standards and converting those to utility standards. 

What we will find is that applying those utilities, those military 

standards to utilities broadly, will be prohibitively expensive. It’s 

very difficult, it’s very challenging, it’s hard to do and it’s very expensive. 

So utilities may still choose, as we’ve heard already, they may 

choose to pick perhaps nine points or something like that and 

harden those points with military standards. But it won’t be practical to support the whole system until we develop some more effective and lower cost alternatives. 

Senator KING. It seems to me this is a place for American ingenuity and inventiveness and creativity to market for somebody. 

Mr. MANNING. Absolutely. 

Senator KING. An important market for homes as well as for the 

grid itself. 

The bill that Senator Risch mentioned mandates a study. I 

should not have used the word mandate, suggest a study involving 

Idaho National Lab and several volunteer utilities on the possible 

importance of putting at certain points in the grid, analog devices, 

which is what saved the grid in Ukraine and that is exactly what 

we are trying to do. It is a bill that came out of our work on the 

Intelligence Committee, both of us are also on this Committee. And 

it is a great bill, Madam Chair. 

But I think, Mr. Speaker, you have done a lot of thinking about 

this. We cannot defend ourselves. We cannot install defenses that 

are so expensive that they far outweigh the risk. How do we get 

products that can solve the problem? 

Mr. GINGRICH. Well, let me use this as an excuse to make three 

quick points, ending on that one, okay? 

Senator KING. Fine. 

Mr. GINGRICH. First, every member of Congress already got 

briefed on the concept of hybrid warfare, what you’re seeing in 

Ukraine. 

Senator KING. Yes. 

Mr. GINGRICH. Because it’s what makes the whole panoply of 

risks come together simultaneously. You don’t know—— 

Senator KING. We are seeing warfare change before our eyes. 

Mr. GINGRICH. That’s right. 

And just as I talked about the paradigm change earlier, from efficiency to looking at resistance, resilience and redundancy, we have 

to rethink from the ground up what we mean and what the military means and what Homeland Security means. 

Two, if I walked in here and said to you, you know, I’ve been 

thinking about how we run our cities and I can’t decide whether 

we’ve got to cut out food inspection in the restaurant, the sewer, 
70 

the fire department or the police. Which one do you think we 

should drop? Because that’s what we’re doing right now in terms 

of this. If we had no choice as we rethink our infrastructure but 

to look at the totality of potential disasters and decide are we going 

to figure out a design that meets the totality. See, you can’t say 

let’s set priorities because the one you don’t pick may be the one 

that kills you. 

Senator KING. Sure. 

Mr. GINGRICH. Lastly, there’s a terrific book. I just did my newsletter yesterday. I very seldom do book reviews in my newsletter 

but it’s called, ‘‘The Weapon Wizards.’’ I recommend it. I’d like to 

get every member of Congress to read it. It is the Israeli capacity 

to innovate and how dramatically they’ve done it and they’re really 

cheap, okay? 

One of the things that I hope Trump is going to bring to the Pentagon, which would, as a Conservative, I’d like to see reduced from 

a Pentagon to a triangle by eliminating 40 percent of its 

redundancies. 

[Laughter.] 

But I mean this quite seriously. 

We start out and we say, since we have to design an absurdly 

expensive, over-engineered obsolete model based on work done in 

1963, if you applied that to the grid you couldn’t afford it. To which 

the correct answer is, well, what if you went out and asked every 

smart, young person in America to come up with a $9 version that 

could be sold on Amazon? 

Senator KING. Exactly. 

You would be interested to know that we have had testimony at 

the Armed Services Committee in the last couple of months that 

Silicon Valley basically will not deal with the Pentagon because it 

is so, I would call it byzantine, but that would be an insult to the 

Byzantium empire. 

[Laughter.] 

Because it is so burdensome and cumbersome, and we are losing 

the innovation race. 

Mr. GINGRICH. And at least half of that is the Congress which 

imposes patterns that are so stunningly stupid that if the Congress 

would look at the things it has passed into law in the past 40 years 

and get rid of half of that and then challenge the Pentagon bureaucracy to get rid of the other half, you’d be startled a year from 

now how rapidly we’d be innovating and how cheap it would be. 

Senator KING. I am shocked you would use the words stupid and 

Congress in the same sentence, Mr. Speaker. 

[Laughter.] 

Mr. GINGRICH. I apologize. 

Senator KING. Thank you, Madam Chair. 

The CHAIRMAN. Thank you. 

Senator Manchin. 

Senator MANCHIN. Very quickly, thank all of you for being here, 

we appreciate it very much. Speaker Gingrich, it is always good to 

have you here. 

Chairman LaFleur, first of all, anybody can answer this and if 

you have any comment to it, but the likelihood of the EMP attacks, 

the likelihood of where we are most vulnerable. I came in a little 
71 

bit late because, as you know, in this place we have competing 

committee meetings. But is it basically from a weapon from another country or is it basically going to be home grown to do damage to the delivery system? Where do you think we are the most 

vulnerable? Or what are you concerned about in vulnerability? 

Ms. LAFLEUR. Well, the so-called suitcase EMP. 

Senator MANCHIN. Yes. 

Ms. LAFLEUR. A handheld device is, obviously, much easier to 

build than a bomb, but it’s also easier to protect against. I think 

some of the these we’re doing, we do know how to put fences on 

substations and cameras and perimeter zones if you have to throw 

something in somewhere, we know how to protect that. So I think 

that’s more likely, but easier, to protect against. 

Senator MANCHIN. You are requiring that because I can tell you 

we have an awful lot of power generating in West Virginia. 

Ms. LAFLEUR. Excuse me? 

Senator MANCHIN. We have a lot of power generating in West 

Virginia. 

Ms. LAFLEUR. Yes. 

Senator MANCHIN. And we light up most of the East Coast which 

they do not know about. 

Ms. LAFLEUR. Yes. 

Senator MANCHIN. If we ever turn the coal off, they would go 

dark. Maybe we should do that. 

Anyway, the substations, I have seen substations that are very 

vulnerable. Are you requiring them to basically solidify that and 

protect? 

Ms. LAFLEUR. What the physical security standard did was required each company, each transmission operator or owner to identify their most critical substations and come up with a specific plan 

to mitigate against physical attack. 

Senator MANCHIN. Do you have anybody that inspects it? 

Ms. LAFLEUR. Excuse me? 

Senator MANCHIN. Does anybody inspect it? 

Ms. LAFLEUR. Yes, we are inspecting and NERC does the first 

audit and FERC—— 

Senator MANCHIN. Well, if I see some vulnerable situations I can 

call you? 

Ms. LAFLEUR. Yes. 

[Laughter.] 

Always. 

But the—so that’s that thing. I think the high-altitude 

HEMP—— 

Senator MANCHIN. Yes. 

Ms. LAFLEUR. The high-altitude EMP is, I don’t remember the 

adjective you used in your question, troubling because we, unlike 

the smaller, we don’t know—— 

Senator MANCHIN. I understand. 

Ms. LAFLEUR. The most—way to protect it. 

Senator MANCHIN. You had something, right? Ambassador? 

Ambassador COOPER. Yes, I don’t know how to put a probability 

statement on but let me give you a couple of facts. 

In 2004, several Russian generals who were experts in EMP, and 

I would note that they did more effective tests on this effect over 
72 

populated areas, in fact, in the ’62, ’63 timeframe than we did. 

They learned more about it than we did. 

They told the commissioners, the EMP Commissioners, that they 

had passed, inadvertently, I think they said, but the information 

on how to design a super EMP weapon that is a low-yield device 

that produces lots of gamma rays. 

Senator MANCHIN. At a high altitude? 

Ambassador COOPER. High altitude, to the North Koreans, okay, 

who in turn, as you know, worked in a direct alliance with Iran on 

everything. 

North Korea, by most estimates, has already anywhere from 10 

to 20 nuclear weapons. We take comfort in the fact that there have 

been low-yield tests in North Korea. 

Well low yield is what you use to produce a super EMP weapon, 

and they allege that they can launch this. They don’t allege, a lot 

of experts I know claim that they can launch this, as Speaker Gingrich said, or put it in a satellite which comes toward the United 

States from our south, our undefended south, okay? We have no defense against that nor do we have a defense against missiles 

launched from ships in the Gulf of Mexico. 

We have not put our—we know how to do it. This is not a matter 

of ignorance. And actually it’s not a matter of cost either, which I’d 

be happy to defend another time, but we know how to do it. We 

just simply are not doing it. We’re deploying what’s called Aegis 

Ashore, and I’m proud of that system because I started it, you 

know, when I was running the SDI program. It’s deployed around 

the world on our ships, it’s deployed on the ground in Romania and 

will be operational in Poland by the end of the year. We have an 

operational site in Hawaii. 

We ought to put a site in Panama City on First Air Force base 

at Tyndall Air Force base where First Air Force has the responsibility of the defense of the United States, give them a missile defense mission too. 

Senator MANCHIN. Do you mind if we bring in—— 

Ambassador COOPER. We know how to do this. 

Senator MANCHIN. Do you mind if we bring you to the Intel, a 

little Intel briefing? 

Ambassador COOPER. I beg your pardon? 

Senator MANCHIN. The Intel Committee for a little briefing, 

would you come? 

Ambassador COOPER. I certainly would. I have my clearances 

still, by the way, so I wouldn’t mind transferring them in. 

Senator MANCHIN. That is great. 

Ms. LaFleur, if I may, while I have got you, just real quick. 

The vulnerability basically is reliability of the grid system. Do 

you feel comfortable of the system of this grid when the vortex almost, the polar vortex, about took us down that one time? I mean, 

where are we today, right now, in your evaluation, with the 

amount of diversity we have going into the grid, as far as electricity sources? 

Ms. LAFLEUR. Well, today we still have quite a bit of fuel diversity. Coal, as you already referred to, plays a very important role 

in baseload in most parts of the country. And we have increasing 
73 

natural gas and increasing renewables. And the system operators 

are learning to run—— 

Senator MANCHIN. Do you consider gas as being a baseload? 

Ms. LAFLEUR. It depends. Some, the big combined cycle, some of 

them are run as baseload run all the time and then there’s also—— 

Senator MANCHIN. But are you concerned? 

I am just saying from the reliability, baseload, to me, means 

uninterruptable power. Coal and nuclear base are uninterruptable. 

They have what they have. Gas is a pipeline delivery system that 

can be targeted by terrorists or any other type of a natural disaster. But you are building, we are building baseload of something 

that could be interrupted. Is that correct? 

Ms. LAFLEUR. It’s correct that to the extent we rely on gas, we 

have to build in fuel security that’s different than the fuel security 

of coal which you can look out and see the pile. 

Senator MANCHIN. Sure, absolutely. 

What is your feeling of comfort on the reliability of the grid? 

Ms. LAFLEUR. I think most parts of the United States are well 

supplied with gas pipelines but we have places where there are 

constraints and I think operating the grid with all the new technologies is something we’re still working on. 

Senator MANCHIN. Does anybody have anything else they would 

like to add? 

Ambassador COOPER. Yes, Senator. 

We’ve talked about E1, E2, E3. E1 is the high frequency, high 

amplitude, narrow pulse that causes damage to solid state electronics. 

Our natural gas pipelines, portions of the grid itself and petroleum pipelines, probably are controlled with little units called 

SCADAs, little, small computers that are vulnerable if we haven’t 

taken special precautions to harden them. And my information is 

we haven’t. So, we have critical infrastructure to the operation of 

the, of all of our grid to these kinds of effects from nuclear, highaltitude explosions. And as I said earlier, I don’t know how to put 

a probability statement on it, but I can tell you the threat is absolutely real. 

I’ve worked on these problems for most of that half century since 

we began seriously improving our strategic systems to deal with it, 

and we set priorities in the Department of Defense. We didn’t try 

to harden everything. We hardened what we thought was the most 

important things. 

In my opinion, in the grid, we should be paying careful attention 

to our nuclear power plants to make sure they aren’t a hazard if 

their grid goes down and they have to shut down—we don’t want 

Fukushimas all over the place. So we need to make sure we have 

power to those, just to keep them safe and then to bring them back 

up to help support—— 

Senator MANCHIN. I want to thank all of you. I appreciate it very 

much. Thank you. 

Ambassador COOPER. Thank you. 

The CHAIRMAN. Thank you, Senator Manchin. 

There has been discussion here about what we see out of Israel 

with their level of innovation. Ambassador Cooper, you have referred to other initiatives around the globe, but in terms of what 
74 

other countries are doing specifically to address a HEMP or other 

EMP-related event. Is anybody, kind of, leading the way here? Are 

there best practices that we might want to be looking to? Who is 

doing some good things? 

Ambassador COOPER. The Israelis, the United Kingdom, I would 

go talk to those folks. We have international conferences every 

year—— 

The CHAIRMAN. To what extent do we cooperate with them then? 

Ambassador COOPER. We meet with them. 

There’s a big difference though, their government tends to control what’s going on. 

The CHAIRMAN. Right. 

Ambassador COOPER. Whereas in this country, as I said to you 

earlier, we have a crazy quilt of electric power companies across 

the nation. Why, I believe, we have to work from the bottom up 

and island, that term we’ve used here, around our nuclear power 

plants, keep them safe, bring them back online. We get 20 percent 

of the nation’s electricity from those plants. And so, that’s a valid 

resource if we lose the entire grid. 

Today, I don’t have confidence that we can do that because we 

don’t have these crazy quilt components connected. So, we have a 

serious problem here, and we have been ignoring it collectively. I’m 

not trying to point fingers at anybody, but that’s the reality. 

The CHAIRMAN. Chairman? 

Ms. LAFLEUR. Thank you for the question. 

We have Memoranda of Understanding with Israel, Norway and 

some other countries, the U.K., to work on these things. 

I would say, in the solar storm area, Scandinavia, is probably, 

the Scandinavian countries are doing the most. Obviously, their location would justify it and—— 

The CHAIRMAN. Well, the United States actually has a location 

up there too. 

Ms. LAFLEUR. Yes, that is correct. 

The CHAIRMAN. It’s called Alaska. 

[Laughter.] 

Ms. LAFLEUR. My feelings exactly. 

Ambassador COOPER. She noticed that. 

[Laughter.] 

Ms. LAFLEUR. That’s why GMD has really been one of my biggest 

priorities, my feelings exactly. 

On the grid security defense area thing, I would agree with the 

Ambassador that Israel, the entire Israeli grid is—it’s just a different society in the way things are run. We have a much more 

open society in terms of how our infrastructure is designed and set 

up, I mean, and so, I think, in security Israel is probably leading. 

The CHAIRMAN. Let me leave you with one question. Again, I am 

going to allow anybody to step in here. Ambassador, you mentioned 

this crazy patchwork that is out there. Some have mentioned the 

imperative of public/private partnership, but in order to have a 

public/private partnership there has to be a little bit of trust there, 

there has to be a willingness to share some information. 

In fairness, I think we have seen some instances where information gets out there and you get burned in the media. Probably the 

most current example is what happened in December in Vermont. 
75 

As I understand it, Burlington noticed an alert about a suspicious 

IP address that had connected to one of their computers. They responded, reported. The next day, the Washington Post somehow 

learns about it. Then you have reports about Russian hackers infiltrating. Later follow-up shows that the IP address was not necessarily linked to Russia. It was not necessarily malicious activity. 

But you really have eroded any trust that may have been out 

there. 

So how do we do a better job of this? How do we work to restore 

this level of trust and build a relationship that is going to be necessary in order to really address this? 

Mr. Wailes? 

Mr. WAILES. Well, I think that we have a perfect example of that 

of the relationship that the industry has built with the Electric 

Subsector Coordinating Council, the Department of Energy and the 

Department of Homeland Security. 

There is no doubt that that was a significant issue and a learning experience for everyone. But I think that one of the things that 

needs to also be taken away is that proves the effectiveness of getting that information out because information came out, you know, 

here’s some suspicious IPs that you need to look for, report to us 

right away. And that function worked. Now was there a communication issue and a potential issue associated with that, yes, and 

I think we’re working on fixing that like we are lots of other issues 

between us. 

The relationship, I think, between the industry, actually within 

the industry and within the industry and the Federal Government 

is stronger than it’s ever been, recognizing we have a lot of common 

issues and we need each other’s help in order to make the nation 

stronger. And I think we’re doing a good job of that. 

We have a long ways to go. There are a lot of threats, a lot of 

issues. But there are just so many examples of how that working 

relationship has worked. And I think, when we talk about that, one 

of the things we should even think about is five years ago you did 

not have a lot of security clearances in the industry. And now, 

thanks to DOE and DHS, even a utility our size has six or seven 

people that would have security clearances. We’re able to do things 

they could never do before, and we’re able to share information 

that we couldn’t do before. So it’s a learning experience. We all understand the communication challenges, and I think we’re on the 

way to, at least for our sector, to do that. 

Now, we also are very interested in trying to build a stronger relationship with those other connected sectors that have issues and 

trying to make sure that we actually look at cross sector coordination, such that the other critical sectors, along with the electricity 

sector, actually can have that same functionality with the government. 

The CHAIRMAN. Well, I am encouraged to hear you say that you 

think things are getting better in terms of providing that level of 

security clearance because we had a hearing, not more than six 

weeks ago, where that issue was raised about the frustration with 

how long it actually took and it was actually a former member who 

was the former head of the Intelligence Committee on the House 

side and was still having trouble getting his clearance. 
76 

Mr. WAILES. I don’t know what the current process is, but the 

number of people from years ago that we got in, through that process, was much higher than through that. 

The CHAIRMAN. Yes. 

Ms. Durkovich? 

Ms. DURKOVICH. Yes, an excellent question. 

And while the incident that you referred to is unfortunate, I 

would say, overall, the trust that has been established between 

government and industry in the partnership is stronger than it’s 

ever been. 

Kevin alluded to many of the activities that we have underway. 

In my former position I actually ran the private sector clearance 

program which is the program that provides clearances to infrastructure owners and operators who have the need to know. When 

I left, I think there were roughly about 3,000 owners and operators 

that had clearances. 

Clearly what happened at OPM has slowed the ability for us to 

provide those clearances in a timely manner. But I think that those 

timelines are clearing up and those clearances, as well as many 

other authorities that Congress granted DHS, and that’s everything from the protected, critical infrastructure information program to the critical infrastructure partnership advisory committee 

which allows us to both share information, to ask for vulnerability 

information from owners and operators to protect it from regulatory purposes from state sunshine laws, from FOIA. 

So we can take that information, we can investigate, we can do 

forensics, we can anonymize and we can push it out. Industry is 

one key part of how we share information. 

As part of the Electric Sector Coordinating Council and all of the 

other sector coordinating councils, we bring industry in on a regular basis to provide them with threat briefings, with classified 

briefings, to help them understand this complex risk environment. 

We can have conversations that are not available to the public 

about what we should be doing to protect our infrastructure. And 

the list really goes on. 

But I think, there’s two important points that I want to end with 

is one, better understanding the intersection of these critical lifelines and the vulnerabilities caused by them and how we can continue to ensure and have plans in place to mitigate cascading impacts in the event of some of the incidents that we’ve been talking 

about. And then, I think, the second piece of this is as we begin 

to modernize our infrastructure and we begin to move to smart cities, I cannot underscore the importance of baking security in at the 

beginning. You need the security people sitting next to the coders, 

the architects and the builders. It is imperative. Security is the 

new normal. 

It will be a differentiator. It will be a differentiator for companies. It will be a differentiator for utilities. It will be a 

differentiator for cities. And it has to be one of the core principles 

as we go about modernizing our infrastructure. 

So, thank you. 

The CHAIRMAN. Good. 

Ambassador Cooper, why don’t you wrap up, please? 

Ambassador COOPER. Okay. Thank you, Madam Chair. 
77 

I just wanted to comment on this last discussion about security. 

I think someone needs to do a serious look at the levels of security 

that is inhibiting this kind of open discussion of what the environments are that the industry has to design against as well as other 

factors. 

I don’t believe that there is an absence of technology to deal with 

the EMP issue in an affordable way. 

And I want for your peripheral vision to just make one more 

point. I absolutely agree with you about the need for trust between 

the people and the parties that have to deal with this issue which 

is why I gave up on trying to get institutions here in Washington 

and even in the states, to deal with this issue. Lots of folks have 

tried, are trying, and are frustrated by the issues that you’ve mentioned. That’s why I’m working very closely on an individual level 

with key people and when I say local, I mean, in three counties 

right now, and we’re going to couple into the NERC exercise this 

November, the GridEx exercise as well, to expand our lessons 

learned upward in South and North Carolina and we’ll go elsewhere. 

I think that we have to wake up to the sense of priority of dealing with the issues. The EMP Commission has looked at the briefings that some of the folks at this table have given. It is their assessment that they’re underestimating the threat, even for the 

solar threat. The magnitude of the E3 component for a nuclear device is larger than for the solar event. So, if we harden the grid 

for a solar threat, we will still leave ourselves vulnerable for the 

other. 

And in addition, you have E1 as a component that threatens the 

solid state electronics throughout our grid and that includes the 

distribution systems for petroleum and natural gas. So, we need to 

deal with this issue in a very, I believe, direct way. 

I think that we have hope that what we’re doing to accomplish 

locally. And when I say island, I want to build an island around 

Duke’s nuclear plant and its hydroelectric plant and coal plant all 

on that lake so that the local people are engaged in working the 

problem. And by the local people I mean the, you know, the mayor, 

the city council at the political level, but Joe Sixpack, who understands what we’re doing through the National Guard and so on. 

Our—general is an electrical engineer graduate of Georgia Tech. 

He understands these issues and he is committed to try to work 

with us and we’ll expand outward from there to other states and 

other locations. I believe that’s the way we have to go to really 

build trust among the key players that are required to cut across 

the patchwork, quilt patchwork, that I tried to describe to illustrate 

earlier. 

And that’s not to argue against initiatives at the state level or 

the federal level or so on. At least that raises consciousness about 

the nature of this threat. 

But my concern is the devil is in the details. And we learned 

hard lessons in the Department of Defense, that it’s not just having 

the right design. It’s not just having the right deployment, and it’s 

not even just having an operational concept that’s important. If you 

don’t test it, I don’t believe it. And we learned through hard experience that maintenance and that sort of operations of operational 
78 

systems that were well designed and deployed, we create holes by 

which EMP can get through. 

So this is a hard problem. We have to choose where we work 

carefully and protect what we need to work to ensure the viability 

of the grid and for the American people. 

The CHAIRMAN. Well, ladies and gentlemen, thank you. I think 

the testimony this morning, the questions and responses back and 

forth, have been very helpful. I think this has been a great discussion. 

I appreciate some of the suggestions that we have, but I also appreciate the urging that we really not let our guard down, recognizing that this is complicated, multifaceted and it requires an attention to it that is really daunting. But just because it is daunting 

does not mean that we should not be working with you, with our 

agencies, with the sector, really across the country. 

I appreciate what you have said, Ambassador Cooper, about really starting out very local and understanding the implications, not 

just those that are tasked on the day-to-day, but helping to educate 

Americans about our vulnerability and what we can do to reduce 

that. 

It is always important here in Congress that we be reminded of 

the urgency and the imperative of our task, and I think we were 

given that message this morning. 

I thank you all for your contributions. 

With that, the Committee stands adjourned. 

[Whereupon, at 11:57 a.m. the hearing was adjourned.] 
(79) 

APPENDIX MATERIAL SUBMITTED 
80 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

FROM CHAIRMAN MURKOWSKI 

1. Not all entities that operate on the bulk power grid have access to 

guaranteed cost recovery through regulated rates, e.g., independent 

power producers. Would there be a means for cost recovery for these 

competitive entities who arc ineligible for rate recovery ensuring we do 

not place a costly anti-competitive mandate upon them? What would 

those be: reimbursement fund, tax deductions? 

Response 

A number of entities hold market-based rate authorization from FERC, allowing 

them to sell power at market-based, rather than cost-based, rates. Entities with 

market-based rate authority have the opportunity to recover their costs, including 

costs for compliance with Reliability Standards requirements, whether through 

individually negotiated power purchase contracts or through offers to sell into 

wholesale energy and capacity markets. The market rules and tariffs governing 

the offers to sell do not preclude sellers from reflecting costs of compliance with 

Reliability Standards in their offers. 

2. Ambassador Cooper has testified about work he is doing in South 

Carolina with Duke Energy, and I am told that American Electric 

Power recently testified in the Texas Senate about work it has 

underway in that State to reduce the vulnerability of the power system 

in that State to EMPs. 

a. Can you comment on this kind of voluntary effort by industry? 

Response 

Voluntary efforts to improve grid reliability and resilience can provide protection 

beyond the requirements of mandatory reliability standards. With regard to 

electromagnetic pulse (EMP), a number of utilities are proceeding with various 

activities to voluntarily study and implement EMP mitigation methods. FERC has 

offered members of industry assistance with these voluntary efforts. Our 

collaboration with industry ean include threat information sharing, assessment of 

best practices and their applicability, and assistance with implementation of 

mitigation measures. This work complements the mandatory reliability standards 

adopted pursuant to section 215 of the Federal Power Act that provide a good 

foundation for protecting the Bulk-Power System. 
81 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

Response 

b. Can you foresee the conditions in which cost recovery for scaledup efforts of this type might be appropriate in rates for FERCjurisdictional transmission service? And if so, could you 

speculate about the potential benefits and necessary cautions 

about such an approach? 

As a general matter, utilities may recover prudently-incurred costs in support of 

grid reliability efforts. With respect to costs associated with mandatory reliability 

standards, section 219(b )( 4) of the Federal Power Act (FP A) specifically allows 

for recovery of "all prudently incurred costs necessary to comply with mandatory 

reliability standards issued pursuant to section 215 [of the FPA]." The statutory 

language is incorporated into FERC's regulations at 18 C.F.R. § 35.35(f). which 

further states that the proposed rates must also be just and reasonable and not 

unduly discriminatory or preferential. Formula rates, which allow for a 

streamlined process for utilities to obtain cost recovery, are one option available to 

industry. Individual utilities may decide whether to use fonnula rates or some 

other rate recovery mechanism. 

In rulemakings approving Reliability Standards proposed by the North American 

Electric Reliability Corporation (NERC), FERC has indicated that cost recovery 

for compliance with mandatory Reliability Standards may be available. For 

example, in Order No. 830, in which FERC approved the second-stage Reliability 

Standard addressing geomagnetic disturbances (GMDs), FERC indicated that 

recovery for prudent costs associated with or incurred to comply with the 

Reliability Standard and future revisions to the Reliability Standard will be 

available to registered entities. In that case, cost recovery would be available for 

costs incurred to mitigate assessed vulnerabilities to a benchmark GMD event. As 

the phrase "prudently incurred costs'' suggests, allowing for cost recovery to offset 

the costs of compliance with mandatory Reliability Standards must be balanced 

against the risk of allowing for recovery of costs unrelated or unnecessary to 

compliance with Reliability Standards. 

FERC has also taken steps to address cost recovery for reliability investments 

outside of the NERC Reliability Standard context. In the wake of the September 

11. 2001 attacks, FERC issued a policy statement on September 14, 2001 

indicating that FERC "will approve applications to recover prudently incurred 

costs necessary to further safeguard the reliability and security of our energy 

supply infrastructure in response to the heightened state of alert." FERC affirmed 

and clarified that policy in a subsequent policy statement issued on April 19, 2004. 

Furthermore, FERC has issued orders to provide rate clarity and certainty 

2 
82 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

concerning efforts to ensure adequate inventories of critical grid infrastructure, 

like high-voltage transformers. 

3. One of the keys to a successful public-private partnership is trust and 

the willingness to share information. I am concerned, however, that 

there is a lack of trust by industry with the government- and for good 

reason. The December 2016 episode with Burlington Electric in 

Vermont is a perfect example. As [ understand it, Burlington noticed 

an alert about a suspicious IP address that had connected to one of 

their computers and responded to that alert by dutifully reporting that 

fact to the government. The same day that they reported the alert, 

however, the Washington Post somehow learned about it and reported 

that Russian hackers had infiltrated the United States' electric grid. 

Later follow-up would show that the IP address was not necessarily 

linked to Russia and there was not malicious activity, but the damage 

to trust had been done. How do we restore and build trust between the 

private sector and government so that this type of information can be freely 

shared without concern about it becoming a media spectacle? 

Response 

I agree that trust between the private and public sectors is critically important to 

information sharing efforts that support grid reliability. As part of its work with 

industry and other stakeholders, FERC conducts analysis and outreach to share 

threat information and best practices for defensive measures to help mitigate risk 

to FERC jurisdictional infrastructure. This collaborative approach facilitates open 

communication with industry representatives. The staff members that engage in 

this collaboration protect industry-generated information using, as appropriate, 

FERC's Critical Energy/Electric Infrastructure Information (CEII) program NonDisclosure Agreements, Transportation Safety Administration's Security Sensitive 

Infonnation (SSI) program, Department of Homeland Security's (DHS) Protected 

Critical Infrastructure Information (PCII) program, and other protection measures. 

4. EMP models are only as good as the data inputs provided. The United 

States has not tested any nuclear weapons since 1992, and no 

atmospheric tests since the Test Ban Treaty of 1963. My 

understanding is that many of our weapon designs have required postdeployment tests to resolve problems- and those problems were 

discovered only because of ongoing nuclear tests at the time. In each 

case, the weapons were thought to be reliable and thoroughly tested. 

How confident are you that the data being inputted into the models 

3 
83 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

with regard to the EMP effects of a nuclear weapon detonation is 

accurate- particularly since we have not conducted an atmospheric 

test since 1962? 

Response 

I cannot comment on the accuracy of this data. As a general matter, however, to 

get the most accurate modeling results, the most up-to-date information should be 

used as input for the models. 

Response 

a. Since most of the data is controlled by the Department of 

Defense and the National Labs, does the private sector have 

access to the data needed to accurately model the potential EMP 

impact and effect of a nuclear explosion? 

FERC docs not have information as to which private sector entities have access to 

the data needed to accurately model the potential EMP impact and effect of a 

nuclear explosion. This data is highly sensitive and access to it is controlled by 

other federal entities such as the Department of Energy and Department of 

Defense. 

Response 

b. My understanding is that most HEMP models arc based on a 

one dimensional, spherically symmetric model, neglect scattering 

effects, and are unable to model 2- and 3-D effects. There is also 

no high-fidelity model that predicts EMP from detonations from 

5 kilometers to 20 kilometers above the Earth's surface. Given 

these shortfalls, how confident arc you in the accuracy of current 

EMP models'? 

I cannot comment on the accuracy of these models. As a general matter, however, 

in order to ensure accuracy, it is impm1ant for models to be as complete as 

possible and to include the relevant known effects. 

FROM SENATOR STABENOW 

1. A primary component oftoday's hearing is our homeland defense 

strategies against foreign states and terrorists, including missile 

4 
84 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

defense and others. For good reason, I presume much of this 

information is classified. However, can you speak further to FERC's 

coordination with the Department of Defense, Department of 

Homeland Security, and other national security entities when it comes 

to sharing information and assessing the risks associated with EMP 

attacks? 

Response 

FERC works closely with our federal partners as well as the appropriate 

stakeholders to better understand the risks and impacts associated with EMP on 

energy infrastructure. These efforts include working closely with federal agencies, 

state partners, and industry to provide classified and unclassified threat briefings, 

assisting with the development and identification of best practices for mitigation, 

and assisting with implementation efforts. 

2. During today's testimony, we heard that EMPs arc a threat to our 

national security. However, the range of impacts appear vast, from 

naturally occurring events causing grid disruptions, up to- and 

including- the aftermath of a high altitude nuclear detonation. 

This Committee has held several hearings in this and previous 

congresses on the threats facing our electric grid and critical energy 

infrastructure. From your perspective, how does the threat posed from 

EMPs compare to other vulnerabilities such as cyber-attacks? 

Response 

Effective protection of the Bulk-Power System requires that we address both 

events that occur regularly, such as attempted cyber incursion, and high-impact, 

low-frequency events that can disrupt reliability. Protection efforts include both 

targeted strategies to deal with particular threats and broader strategies to improve 

grid resilience and recovery through better planning, coordination, and operational 

awareness. 

EMPs and cyberattacks share the potential for having significant, widespread 

impacts on energy infrastructure. Cyberattacks can be perpetrated from anywhere 

in the world, and for this reason they are very ditiicult to attribute to a malicious 

actor because of the level of anonymity that can be provided with internet 

communications. In addition, sophisticated hacking tools are becoming more 

widely available and the cyber threat is constantly evolving making such attacks 

more versatile. It is important to note that cyberattacks are made continually 

against energy infrastructure, although none to date have caused wide-spread or 

long-lasting intcn·uption of service in the United States. The impact of an EMP 

5 
85 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

attack can be equally devastating or even exceed that of a cyberattack. 

Government studies and reports, such as those from the 2008 EMP Commission 

and the Government Accountability Office (GAO), cite risks caused by a manmade EMP or a naturally occurring solar weather event that could have a severe 

impact on the nation's electric grid as well as other critical infrastructures. In fact, 

GMD events are inevitable, with their only uncertainty being their timing and 

severity. 

Considering the potentially wide-spread and long-lasting impact of either a cyber 

or EMP event, both threats should be addressed to more fuJly protect the security 

and ensure the resilience of the Bulk-Power System and critical energy 

infrastructure. 

FROM SENATOR DAINES 

1. I want to take this opportunity to highlight some road blocks my state 

is facing in addressing these issues. As you stated in your testimony 

FERC and NERC are taking steps to address grid security as it relates 

to GMDs and EMPs, and they have already taken steps to address 

issues of physical protection, including vegetation management and 

cyber protection. Unfortunately, while existing standards and 

directives are well intentioned there have been major roadblocks. Our 

small Coops are finding it hard to participate in cyber discussions, and 

while FERC has strict vegetative management guidelines, our Coops 

are not able to cut trees or responsibly manage areas around 

transmission lines due to challenges with federal land managers and 

costly liability requirements. And, by the way vegetation-related events 

are currently one of the main causes of blackouts. Can you expand on 

the FERC and NERC standard for physical protection on vegetative 

management? Is there cooperation with local utilities and federal land 

managers? 

Response 

The Energy Policy Act of 2005 gave FERC authority to review and, if appropriate, 

approve Reliability Standards developed by an Electric Reliability Organization 

(ERO). Upon approval, the Reliability Standards become mandatory and 

enforceable for the users, owners, and operators of the Bulk-Power System. 

FERC, the ERO, or Regional Entities working on behalf of the ERO can enforce 

FERC-approved Reliability Standards. In 2006, FERC certified NERC as the 

ERO and has approved Reliability Standards proposed by the ERO, including the 

6 
86 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

ctment Reliability Standard for vegetation management, F AC-003-4 

(Transmission Vegetation Management). 1 

FAC-003-4 generally applies to all transmission lines operated at or above 200 

kV, plus select lower voltage lines. The Reliability Standard explicitly applies to 

transmission lines that cross lands owned by federal entities. FAC-003-4 requires 

maintenance of a minimum vegetation clearance distance between power lines and 

trees to minimize disruption of electric service due to vegetation contacts with 

transmission lines. However, it does not prescribe how the transmission line 

owner must meet the performance requirement. It only sets a minimum 

requirement for vegetation management programs, i.e., that they conduct 

inspections and meet the required clearances. Vegetation management practices 

are usually defined by the specific right-of-way agreements that the transmission 

line owner has secured with the property owner subject to any state or local 

regulations. Further, Montana's co-ops must comply with any currently applicable 

vegetation management regulations and environmental ordinances established by 

the State of Montana and/or local jurisdictions, to the extent they do not conflict 

with the PERC-approved Reliability Standards. 

There is coordination between utilities and federal land managers. For instance, in 

2016 a memorandum of understanding (MOU) on vegetation management for 

power line rights-of-way on federal lands was agreed to by the Edison Electric 

Institute, Utility Arborist Association, United States Department of the Interior 

(National Park Service, Fish and Wildlife Service, Bureau of Land Management), 

United States Department of Agriculture Forest Service and the United States 

Environmental Protection Agency. The MOU addresses industry concerns 

relating to vegetation management and its ability to deliver reliable electric 

transmission. 2 

The purpose of the MOU is to facilitate cooperation and coordination among the 

parties regarding vegetation management within and immediately adjacent to 

existing and future power line rights-of-way and associated facilities. One goal of 

the MOU is to facilitate implementation of cost-effective and environmentally 

sound vegetation management plans, procedures, and practices for power line 

rights-of-way that will reduce adverse environmental and cultural impacts while 

1 Reliability Standard F AC-003-4 is available at 

http:! /www .nerc.com/ _layouts/PrintStandard.aspx?standardnumber=F A C-003-

4&title=Transmission Vegetation Management&jurisdiction=United States. 

2 The MOU is available at 

http://www .eei.org/issuesandpolicy/environment/land/Documents/EEI _ MOU _FIN 

AL_Signed _ 09.29.16.pdf. 

7 
87 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

enhancing the ability of utilities to provide uninterrupted electrical service to 

customers and address public safety. The MOU also addresses the use of 

incorporating vegetation management practices into the existing and future rightsof-way grants/authorizations across Federal lands. While the Montana coops are 

not signatories to the MOU, it may provide a framework for the coops to work 

with federal land managers. 

2. How can we incorporate our small and rural Coops into the 

conversation so that if or when we do craft standards for events like 

EMPs and GMDs that they are attainable and cost effective enough for 

or small and rural Coops to implement? 

Response 

I think it is important that interested parties have an opportunity to meaningfully 

participate in the development of reliability standards. As a general matter, I 

believe that public power entities are well-represented in the NERC standards 

process, but I agree that we should endeavor to ensure that those standards are 

attainable and cost effective for all utilities that must comply with them. 

Many small and rural coops mainly own only distribution facilities. FP A section 

215 authorizes the Commission to approve Reliability Standards for the BulkPower System, and excludes facilities used in local distribution. Thus, Reliability 

Standards would typically not apply to facilities owned by small coops. In 

addition, small coops are often represented in reliability and regulatory issues by 

their trade organization, the National Rural Electric Cooperative Association 

(NRECA). So, while a small coop may be limited in its ability to represent itself~ 

it is represented by NRECA, which is an active participant before FERC and in the 

NERC stakeholder process. 

There are some large coops that own significant transmission and distribution 

facilities. Under NERC's rules for the development of new or modified 

Reliability Standards, NERC affords participants due process, openness and a 

balance of interests. The drafting meetings are open to the public, and all 

participants (either in person or by phone) can present their concems. In addition, 

in the approval process at FERC, proposed Reliability Standards are considered in 

an open process that allows for public comment as part ofFERC's consideration 

of a proposed standard. In both of these processes, NRECA and the coops 

affected by Reliability Standards can participate in the drafting and approval 

processes. For example, Tri-State Generation and Transmission Association, Inc. 

submitted written comments to FERC in the case that resulted in approval of a 

Reliability Standard addressing planning for a 1-in-1 00 year GMD event. 

8 
88 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

FERC is also actively involved in effmis beyond its Reliability Standards process 

and has worked collaboratively with NRECA and the American Public Power 

Association. FERC works closely with om federal partners as well as the industry 

to better understand the risks and impacts associated with EMP on energy 

infrastructure. These efforts include providing classified and unclassified threat 

briefings, assisting with the development and identification of best practices for 

mitigation, and helping with voluntary implementation efforts. 

FROM SENATOR CORTEZ MASTO 

1. Chairwoman LaFleur, thank you for your testimony. You spol{e about 

FERC's work with state and local authorities on the risk of 

electromagnetic pulse (EMP) events, through briefings and developing 

best practices. I'm interested in hearing more about what the federal 

government is doing to ensure that state and local officials have real 

time updates on risks to the electric grid, either through EMP events, 

cyberattacks or other catastrophic events. 

Response 

a. You spoke during the hearing about the information the 

National Oceanic and Atmospheric Administration (NOAA) 

provides to state officials regarding warning signs of a naturally 

occurring EMP event. Does a similar information sharing 

process exist for warning signs of a potential manmade EMP 

event, from a state or non-state actor'? 

I am not aware of any such system for information associated with man-made 

EMP threats. 

Response 

b. In addition, I know that getting information to the appropriate 

classification level can at times be a challenge for information 

sharing from the federal to state and local governments. Is the 

information shared in a timely enough manner where it could be 

properly acted upon? 

The National Oceanic and Atmospheric Administration and the Space Weather 

Prediction Center is the official U.S. Government source for distribution of space 

weather related (e.g., GMD) information. A well-established notification process 

is in place that directly provides timely information to any subscriber including 

state and local government officials. As for EMP, cyberattack, or other 

9 
89 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

catastrophic events, DHS has established Fusion Centers to operate as state and 

major urban area focal points for the receipt, analysis, gathering, and sharing of 

threat-related information between federal, state, local, tribal, territorial, and 

private sector partners. 3 Fusion Centers are operational in all 50 states as well as 

the District of Columbia, Guam, Puetto Rico, and the U.S. Virgin Islands. 

2. The security of our infrastructure is of critical importance to me, 

particularly since so much of the economy in my home state of Nevada 

relies on electricity to keep tourism, gaming and the strip going around 

the clock. 

In 2007, the Idaho National Lab led a research project that simulated a 

cyberattack on the electric grid. During the effort, as you likely know, 

they demonstrated the vulnerability of much of our electric grid to 

cyber weapons. Since that time, companies, as well as federal, state 

and local governments have taken steps to fortify our defenses against 

cyberattacks, but there is more to do. 

Can you talk about the likelihood of an EMP attack on our grid as 

compared with a cyberattack? 

Response 

EMPs and cyberattacks share the potential for having significant impacts on 

widespread portions of PERC jurisdictional infrastructure. Each has attributes that 

make them easier or more difficult to perpetrate, thereby affecting their likelihood. 

Sophisticated cyberattacks can be perpetrated from almost anywhere in the world. 

Cyberattacks can be difficult to attribute to a malicious actor because of the level 

of anonymity that can be provided through internet communications. In addition, 

sophisticated hacking tools are becoming more \Videly available and the cyber 

threat landscape is constantly evolving, making such attacks more versatile. In 

addition, cyberattacks are constantly made against critical energy infrastmcture, 

although none to date have caused wide-spread or long-lasting interruption of 

interstate electric service in the United States. Although the attacks are 

sophisticated and fast-changing, mitigation practices such as the adoption of 

NERC's Critical Infrastructure Protection Reliability Standards, National Institute 

of Standards and Technology standards, and others are well-accepted and have 

been widely implemented on critical energy infrastructure in the United States 

making it more difficult for an attack to succeed. 

3 Information regarding Fusion Centers is available at 

https ://www. dhs. gov /state-and-major -urban-area-fusion-centers. 

10 
90 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

EMP attacks require either a physical presence near the facility being attacked (as 

in a suitcase attack), or a presence at a more distant location using a platform such 

as an aircraft 4 or ship, 5 or the ability to gain control of a nuclear device. This 

required physical presence, access to an aircraft or ship, or access to nuclear 

capability typically makes an EMP attack have a higher barrier to entry. The 

impact of an EMP attack, however, can be equally devastating or even exceed that 

of a cyberattack. Government studies and reports, such as those from the EMP 

Commission and GAO, cite risks caused by man-made EMP or a naturally 

occurring solar weather event as potentially having a severe impact on the nation's 

grid as well as other critical electric infrastructure. 

Because EMPs can have a higher barrier of entry, easier attribution, and require 

some level of physical proximity, or access to nuclear weapons, they are more 

difficult to implement. However, the results of an EMP attack may be more 

severe than a cyberattack. 

By comparison, cyberattacks against critical energy infrastructure are happening 

continually, being used by other countries, terrorist groups, criminal gangs, 

hacktivists, and others. Recognizing that the work to protect against cyberattacks 

must continue and evolve, the widespread acceptance and implementation of 

effective mitigation measures have thus far prevented a cyberattack causing a 

significant outage in the United States. 

As noted above, effective protection of the Bulk-Power System requires that we 

address both events that occur regularly, such as attempted cyber intrusion, and 

high-impact, low-frequency events that can disrupt reliability. Considering the 

potential wide-spread and long-lasting impact of either a cyber or EMP event, both 

threats should be addressed to more fully protect the security of critical energy 

infrastructure. 

4 See http://vvww. boeing.com/features/20 12/1 0/bds-champ-1 0-22-12.page. 

5 Report of the Commission to Assess the Threat to the United States from 

Electromagnetic Pulse (EMP) Attack: Critical National Infrastructures (2008) at 

2, http://www.empcommission.org/docs/ A24 73-EMP _Commission-7MB. pdf. 

II 
91 

QUESTIONS FOR ACTING CHAIRMAN LAFLEUR 

05.04.17 Committee on Energy and Natural Resources 

3. Given that an EMP attack needs to be delivered by a physical 

denotation device, in what instances would a country or terrorist group 

usc an EMP attack as opposed to a cyberattack? 

Response 

I am hesitant to speculate on the circumstances in which a country or terrorist 

group would choose one form of attack over another. As I stated earlier, however, 

both could result in significant grid impacts and I believe both should therefore be 

addressed. 

12 
92 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to the Honorable Newt Gingrich 

Question from Chairman Lisa Murkowski 

Question: One of the keys to a successful public-private partnership is trust and the willingness 

to share information. I am concerned, however, that there is a lack of trust by industry with the 

government- and for good reason. The December 2016 episode with Burlington Electric in 

Vermont is a perfect example. As I understand it, Burlington noticed an alert about a suspicious 

IP address that had connected to one of their computers and responded to that alert by dutifully 

reporting that fact to the government. The same day that they reported the alert, however, the 

Washington Post somehow learned about it and reported that Russian hackers had infiltrated the 

United States' electric grid. Later follow-up would show that the IP address was not necessarily 

linked to Russia and there was not malicious activity, but the damage to trust had been done. 

How do we restore and build trust between the private sector and government so that this type of 

information can be freely shared without concern about it becoming a media spectacle? 

Answer: We should expect a lot more hacking from a variety of sources. The United Stated 

CyberCommand has to develop a real time validator that can investigate and report. The hackers 

at Carnegie Mellon are a good start. 

Question from Senator Debbie Stabenow 

Ouestion: During today's testimony, we heard that EMPs are a threat to our national security. 

However, the range of impacts appear vast, from naturally occurring events causing grid 

disruptions, up to- and including- the aftermath of a high altitude nuclear detonation. 

This Committee has held several hearings in this and previous congresses on the threats facing 

our electric grid and critical energy infrastructure. From your perspective, how does the threat 

posed from EMPs compare to other vulnerabilities such as cyber-attacks? 

Answer: EMP is a catastrophic disaster if it occurs. True cyber dominance would also be a 

catastrophic disaster. We cannot set priorities. We have to investband organize to beat both. 
93 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

Questions from Chairman Lisa Murkowski 

Question 1: Ambassador Cooper, in your written testimony, you note that a man-made EMP is 

significantly different from natural EMP events, or Geomagnetic Disturbances. Could you please 

explain your reasoning on this matter? 

• A Geomagnetic Disturbance (GMD) involves multiple low frequency pulses lasting 

minutes over a period of hours to days. Warning is provided by an increase in solar 

activity 18-72/wurs in advance-with a significant update 20-4.5 minutes before 

charged particles hit the earth. It couples energy to the long lines of the grid, which is 

then focused on substations and, in particular, threatens the large generators and 

transformers. It also will affect long haul communications and the internet. These 

effects can be regional or worldwide, depending on the duration of the solar storm. 

Current magnitude estimates being provided by NERC to the electric energy producers 

are judged by the EMP Commission to be considerably low. These effects are of larger 

intensity at higher latitudes and near large bodies of water. 

• High Altitude EMP (HEMP) pulses include a similar low frequency pulse (called the 

E3 component l!{the HEMP pulse) lifsubstantially larger amplitude-by a factor of 

several greater than current NERC estimates), plus: 

o An extremely high frequency pulse (with a pulse width lif JOOs ofnanosecomls) 

called the El component, effectively an electric "shock" that poses a major 

threat to all solid state electronics, especially the SCADA systems that control 

key components tif the grid--e.g., generation stations and their natural gas afl(/ 

petroleum pipeline fuel sources. It also poses a significant threat to 

telecommunications, computers and data centers. Note: This faster El 

component arrives before the E2 allll E3 components and will interfere with 

control systems needed for safe grid shutdown, potentially leading to severe 

damage tifthe power generation plants, unless there is adequate protection 

against El effects. 

o A midrange ji·equency pulse, called the E2 component, is similar to lightning 

ami can be protected against via typical lightning arrestors. But care must be 

taken to avoid degradation from the effects of the earlier arriving El pulse. 

• HEMP effects are regional to continental, depending on the height-of-burst lif the 

attacking weapon(s). Geographic coverage increases with weapon yield and E3 

intensity increases at lower latitudes (unlike GMDs tlwt decrease at lower latitudes). 

• Bottom line: Hardening against GMD leaves the grid vulnerable to HEMP; hardening 

against HEMP will also protect against GMD. 

Thus, the current govemment and industry focus (/II grid GMD protection while 

ignoring HEMP is shortsighted to say the least. 
94 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Elcctromaguetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

Question 2: Can you tell us more about your work in South Carolina and with Duke Energy and 

the important lessons learned? Should the federal government put more resources into that type 

of approach? Should we be looking at similar pilot projects to the one you have ongoing with 

Duke Energy? What recommendations do you have for the government and private sector to 

collaborate in order to emulate the success your efforts in South Carolina have enjoyed? 

• First, please permit me to recup my motivation for and the progress of our Lake Wylie 

Pilot Study, which I hope will become 11 model that others can and will follow. 

• As indicated in my written testimony, I began this South Carolina effort understanding 

that neither Federal nor State efforts were dealing effectively with the existential EMP 

threat-nor were they likely to do so in my lifetime. In my written testimony I quoted 

liberally from an Apri/20, 2017letter from the EMP Commission Chairman to Energy 

Secretary Rick Perry specifying several importunt criticisms of ongoing pertinent 

activities hindering progress in dealing effectively with the EMPIGMD threat. 

• For such reasons, I concluded years ago thut we had to address the problem 'trom the 

bottom up," working with locul (e.g., city und county level) authorities und citizens 

themselves to gain 1111 understanding ~~{the threat and how they need to engage those 

who provide their electricity to assure the viability of their critical civil il!f'rastructure, 

in case of a major electric grid shutdown. Without considerable emergency 

management cooperation at the local level, there will be little hope for most citizens 

who today depend 011 electricity for !!fe-line services in our "just-in-time" economy. 

• Moreover, l began with severul biases, based on a l{fetime of pertinent experiences 

ussociuted with EMP issues, which guide my assessments 11111/ recommendations. 

o I lwve no confidence that we will ever harden the entire grid, so l believe we lwve to 

establish priorities-/ give top priori(~' to assuring the safety and viabili(v of our -100 

nuclear power plants that produce uhout 20-percent of the nation's electricity, and half the 

electricity tif my home state, Soath Carolinu. Titus, I believe our top priori(V is to build 

protected "islands" within the grid uround oar nuclear power plants, the vust maiori(v of 

which are in the Eastern Interconnect tif the grid. 

o To assure the viability of the nudear power plants inun indefinite grid shutdown, 

we must first ussure their cooling wuter systems ure viable to avoid Fukusltima-like 

disasters. Then, we must assure that sufficient generating power and loading 

conditions ure provided by the surrounding "island" in the grid-and linked with 

other critically important elements of the grid to ensure they are available to restart 

the nuclear power plants-and other power plant~~ which will shut down to protect 

themselves if the grid goes down. 

o I don't believe anything that isn't regularly tested and subjected to independent 

criticul review-effective design ami deployment is not enough; truly effective 

testing and maintenunce are major chullenges. 

• Over the past two years, I have developed excellent relationships with key electrical 

engineering professors ut my alma mater Clemson University and several Duke 

engineers (including Clemson graduate.\~ who ulso are concerned about tllis threat2 
95 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

and through them access to other university graduate programs and other energy 

companies. We agreed on how we could proceed with a meaningful "bottoms-up" 

program to assure the viability of three Duke Energy power plants on Lake Wylie, on 

the Catawba River that runs between North and South Carolina-and of course key 

transmission infrastructure that interconnects those nuclear, hydroelectric and coal 

power plants ami others to their customers. Duke Energy's senior management has 

agreed to share broadly the lessons teamed from this important "Lake Wylie Pilot 

Study," described in greater detail in my written testimony. I want to make clear I was 

not and am not selling anything to or ji1r Duke Energy and would not take money from 

them if they offered it. I just want to cut through the morass described above, and 

provide hope that ll{V grandkids can survive if we experience an EMP attack or GMD 

event. I know that all our citizens want this objective met. 

• A critically important lesson that we have learned is that Duke Energy needs the active 

participation/cooperation of other Energy Utili~v Companies and Electric Cooperatives 

(CoOps) that actually maintain critical infrastructure that delivers Duke's electricity to 

key customers, e.g., the water/wastewater infrastructure that supports local hospitals 

and other critically important service activities, including many citizens themselves. 

Happily, we are now working with these key individuals in the local area around Lake 

Wylie-including the Deputy Mayor (a Clemson electrical engineering graduate) of 

Rock Hill, a major suburban city neighboring Charlotte, the home of Duke Energy's 

corporate headquarters. Moreover we are achieving cooperation of the county sheriff 

and key local citizens. The SC Adjutant General (a Georgia Tech electrical engineer) is 

supportive of our efjiJrt, and we are working with his emergency management staff to 

support their participation in November's GRIDEX-IV national exercise focused on 

the physical anti cyberattack threats to the grid. Associated co11tacts will he helpful in 

SC and beyond. We expect a regional follow-on exercise involving the EMPIGMD 

threat, and also including at least the NC emergency management community. 

o I cannot overstate the importance of engaging these local people in any eff'ort to 

improve the viability of the electric grid-notjust locally but in networking 

throughout the nation. Several thousand electric utility companies and CoOps 

deliver electricity via their il!frastructure to key customers and private citizens 

around the nation. We hope to demonstrate how to meet this complex clutllenge. 

o I also can't overstate the important role that informed and concerned local citizens 

can play. For example, a retired Physician, who has come to understand the threat 

and the urgent need for local authorities to be active(!' involved, has provided a 

great deal of support with the local citizens as well as city and county officialsand through his growing involvement in SC statewide activities, .such as the 

GRID EX-IV exercise. These connections also involve the National Guard, thereby 

enabling lessons learned to be propagated through multistate and NORTHCOM 

connections, potentially to he included in a national network. 

3 
96 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

• My short answer to your direct question is that I believe we will indeed produce a 

"bottom's up" pattern worth considering by other states. I personally believe that this 

approach has more promise of success than anything tit at can be produced by the 

currently discordant activities of the Federal Government. Congress could be helpful 

in addressing that important shortfall-in particular by extending to permanent status 

the EMP Commission and placing it in the White House with a charter to provide 

critical assessments of efforts of the several departments with related responsibilities 

and to recommend to the President and Congress measures to rectify shortcomings. 

Question 3: One of the keys to a successful public-private partnership is trust and the 

willingness to share information. I am concerned, however, that there is a lack of trust by 

industry with the government- and for good reason. The December 2016 episode with 

Burlington Electric in Vermont is a perfect example. As l understand it, Burlington noticed an 

alert about a suspicious IP address that had connected to one of their computers and responded to 

that alert by dutifully reporting that fact to the government. The same day that they reported the 

alert, however, the Washington Post somehow learned about it and reported that Russian hackers 

had infiltrated the United States' electric grid. Later follow-up would show that the IP address 

was not necessarily linked to Russia and there was not malicious activity, but the damage to trust 

had been done. How do we restore and build trust between the private sector and government so 

that this type of information can be freely shared without concern about it becoming a media 

spectacle? 

• I agree there is a maJor problem in assuring public trust in the government to address 

this, in n~y Judgment, existential threat. Moreover, their skepticism is well founded. 

Washington (in both Executive and Legislative branches) is failing to address the issue 

as I discussed in my testimony-am/few state governments acknowledge the existential 

threat, much less deal with it. This general dysfunctional leadership is why I believe we 

must actually work the problem "from the bottom up," as I test(fied and discussed in 

my answer to Question 2. It would help !{the key departments, DoD, DHS ami DOE, 

would get their collective act together. But I believe this will only happen with strong 

leadership fi·om the White House. Extending the EMP Commission and placing its 

secretariat in the White House with access to the President would help tremendous(v. 

Question 4: EMP models are only as good as the data inputs provided. The United States has 

not tested any nuclear weapons since 1992, and no atmospheric tests since the Test Ban Treaty of 

!963. My understanding is that many of our weapon designs have required post-deployment 

tests to resolve problems and those problems were discovered only because of ongoing nuclear 

tests at the time. In each case, the weapons were thought to be reliable and thoroughly tested. 

How confident are you that the data being inputted into the models with regard to the EMP 

effects of a nuclear weapon detonation is accurate- particularly since we have not conducted an 

atmospheric test since 1962? 

4 
97 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

• The usable HEMP data from our most pertinent 1962 South Pacific high-altitude 

nuclear tests were sparse. However, with theoretical calculations we have always been 

able to match that limited data. With improvements in measurement uncertainty 

evaluations (affecting the quality of the data), the theoretical calculations and data 

(peak values and entire waveforms) have agreed within 20-percent. We subsequently 

obtained relevant data from low-altitude, low-yield testing at the Nevada Test Site, 

against which we could evaluate our theoretical models for at least "source-region" 

EMP. And that experience helped to build additional confidence in our HEMP 

calculations. My own personal e'l:perience was, like all who sought to conduct 

mecmingful nuclear tests-including underground nuclear tests, to try to avoid the 

EMP disruption of instrumentation intended to measure other effects, e.g., to 

understand X-ray and Blast and Shock effects. 

• I understand the Soviets/Russians executed better planned and instrumented HEMP 

experiments. They had an advantage since they broke-out o,(the 1958tttmospheric test 

moratorium with a well-planned 1961 test series, and then our "knee-jerk" highaltitude test response produced limited results. Because our tests exposed mostly ocean 

areas rather than large land areas with extensive long-line power and communications 

infrastructure, we did not experience the system network effects that did the Soviets in 

their high altitude test series. President Kennedy signed the Limited Test Ban Treaty on 

October 5, 1963, terminating indefinite(v our ability to do better HEMP testing. 

• In the early wake of the end r~ftlte Cold War in the 1990s, we obtained at least some of 

that more extensive information from Russian scientists. And the EMP Commission is 

now looking into how best to use that information to provide more confident estimates 

rif EMP environments and ~ystem response information that slwuhl be helpful to the 

electric power companies seeking to protect their infrastructure from EMP effects. 

• Moreover, Russian generals informed EMP Commissioners in 2004 that they /tad 

passed design information on "super EMP weapons" to North Korea and anticipated 

that they would have such a weapon in a few years-that was 13 years ago. Now, the 

electric power industry should be taking these capabilities into account in assuring 

their infrastructure can operate through-or be restored after-a HEMP attack. 

a. Since most of the data is controlled by the Department of Defense and the National Labs, 

does the private sector have access to the data needed to accurately model the potential 

EMP impact and effect of a nuclear explosion? 

Much is already public-was made in the 2008 EMP Commission Report. 

Additional important data ami EMP hardening infornllltion are, in my opinion, 

overclassified and should be made available to the private sector ASAP. For 

example, the "For Official Use Only" DoD EMP Engineering Handbook, MILHDBK-423 should certainly be completely unclassified. Our enemies surely have 

5 
98 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

long ago had it. Moreover, tlte EJ portion of the DoD EMP Environment Standard, 

MlL-STD-2169C, should be declassified and provided to the energy companies 

seeking to harden their critical infrastructure. 

b. My understanding is that most HEMP models are based on a one dimensional, spherically 

symmetric model, neglect scattering effects, and are unable to model 2- and 3-D effects. 

There is also no high-fidelity model that predicts EMP from detonations from 5 

kilometers to 20 kilometers above the Earth's surface. Given these shortfalls, how 

confident are you in the accuracy of current EMP models? 

• EJfP experts tell me that tlte DoD EMP environment standard established decades 

ago is reliable for predicting the El component of the EMP pulse, and that it is well 

represented by 1 D full-physics models. in fact, 1 understand that it is a validated (by 

experiment and 2&3-D calculations) high frequency approximation for the 3-D 

model, referred to as the Longmire-Karzas-Latter model for El generation. 

• In the mid-1960s a combination of 1-D and 2-D codes were developed at the Air 

Force Weapons Laboratory (AFWL), RAND, and Mission Research Corporation 

(MRC) that accurately predicted the EMPfields produced by air and ground 

vertical asymmetry effects for nuclear tests, over the altitude range from zero to 

exo-atmospheric altitudes. Within the atmosphere, the geomagnetic effect is smaller 

than tlte vertical asymmetry effects, but has been accurately predicted by the same 

1-D approximation used to predict the fields produced by exo-atmosplteric nuclear 

explosions. For explosions where the gamma rays interact with the ground, another 

1-D approximation, called the Graham-Schaefer effect, has accumtely predicted 

the close-in near-surface fields, and has been verified in underground nuclear 

testing. Together, these constitute high-fidelity models of the EMP fields produced 

by atmospheric and exo-atmospheric nuclear explosions. 

• Two independent families of EMP codes were developed and supported by the 

Defense Nuclear Agency and the USAF/AFWL to enable comparative error 

analysis that yielded results within lfJ-30% of each other. The Congressional EMP 

Commission funded SAIC physicists to recheck the physics oftltese analyses and 

found them to be correct. Thus, I conclude that current theoretical analyses are 

sufficiently accurate to confidently design, develop, deploy and operate critical grid 

infrastructure to counter El pulse. That said, I would insist on prudent defenseconservative designs. 

• I understand that the EMP Commission is completing reports on the E2 and EJ 

components of the HEMP pulse, with an expectation that current calculations will 

provide accurate results that are expected to be validated within a factor(~{ 2. 

Again, I would insist on conservative designs to counter E2 and EJ. 

6 
99 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

Question 5: Are there military applications to address HEMP or other EMP-related events that 

are not being made available to civilians? If so, how do we lift that barrier? 

• As noted in my answer to question 4a, we should declassify as much of the DoD 

information on EMP effects and hardening technology as possible. I urge that 

Congress demand that the EMP Commission make spec(fic recommendations 011 this 

matter as part of their June 2017 report, if not sooner. 

Question 6: Do you believe any additional research is needed on EMP threats? 

• I don't want to overstate the issue, but I believe most of the current "research" by the 

DOE labs ami EPRI is at best reinventing what has already been accomplished by 

DTRA and the military service laboratories (AFRL, ARL, NSWC) over the la.~t 50 

years. This DOE redundancy is actually unhelpful and could be eliminated my making 

that DoD information available to the energy companies that need it to do their job. As 

noted above, the EMP Commission can make an enormous{v important contribution by 

providing specific recommendation in its June 2017 report, ({not sooner. 

Question from Senator Debbie Stabenow 

Question: During today's testimony, we heard that EMPs are a threat to our national security. 

However, the range of impacts appear vast, from naturally occurring events causing grid 

disruptions, up to and including- the aftermath of a high altitude nuclear detonation. 

This Committee has held several hearings in this and previous congresses on the threats facing 

our electric grid and critical energy infrastructure. From your perspective, how does the threat 

posed from EMPs compare to other vulnerabilities such as cyber-attacks? 

• E."MP is the "800 pound gorilla" on the list of threats (a view expressed by AT&T 

officials, with which 1 agree). It t~[fects the long line systems similarly to solar storm 

GMD events (but 1~{ higher amplitude), and in addition EMP has a high frequency 

punch (the El Component) that will take out office equipment, data centers, and 

machine control electronics. Today, virtually none of our critical ci1•il infmstructure is 

protected. As noted above, the low-frequency E3 component is substantially larger than 

the G}'dD threat, which is today being underestimated by NERC-so GMD protection 

may not, probably will not, suffice even for E3 protection. 

• From a technical standpoint, EMP ca11 induce over-voltages on everythingji·om 

computers to heavy machinery controllers to data networks comprising the internet, to 

telephone networks, electric power plants and substations. And while not all electronic 

systems will upset or burnout, a large enough fraction will fail such that, without 

protection, cascading effects can bring the U.S. economy, or any economy, to a 

7 
100 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

grinding /wit. Among critical infrastructure systems, the power grid is probably the 

most certain to fail. Without electric power, most other infmstructures will be 

debilitated. Without protection, the power grid will be out f!(servicefor significant 

portions of time-as explained in the 2008 EMP Commission report. 

• DHS has identified 16 infrastructures, and of these the electrical power system and 

communication systems are arguably the most important to the nationul enterprise, 

but, ironically, they are also the most vulneruble. The reason is that they depend upon 

long lines, and since EMP levels are measured in Volts per meter, so the longer the 

lines in meters the higher the voltage induced on the lines. Intuitively, any system that 

has long lines (e.g., electric power or communications) will be the most vulnerable. 

• We know how to protect systems against EMP. The DoD has been doing it since the 

1960s, and has developed E.MP environment and protection engineering standard\', 

Simply put a shield around critical equipment; protect all the wire penetrations; 

include backup power systems am/use fiber optics as much as possible. We know how 

to protect against solar storms (GMD) because Sweden and Canada have protected 

their grids against solar storms for years. Since we know how to protect against G,MD 

with capacitive blockers and reactive power compensators, we know how to protect 

against tile EMP E3, though we must take care not to underestimate its magnitude. 

And we must test regularly to assure even the best standards of operations are 

maintained after sound hardening capabilities are deployed. 

This is not to argue against protecting the grid against cyber and physical attack. 

Indeed, if there is an EMP attack our adversaries, who are well informed and 

competent, undoubtedly will include cyber ami physical attack precursors to confuse us 

and disrupt our response not on(l' to those attacks but to the pending EMP attack itself. 

The best approach is a multi-hazzard approach since the same high impact system 

failure locations are vulnerable to EMP, cyher and physical attacks. 

Question from Senator Steve Daines 

Ouestion: You stated that although EMP attacks arc known to be included in North Korea's 

military doctrine and planning, bureaucracy and inaction have precluded DoD, DoE, and DHS 

from developing an effective EMP defensive posture. I serve on committees with jurisdiction 

over all three of those departments. From your perspective, what red tape needs to be cut to get 

the right leaders in a room and address this issue? 

• I believe that the Executive Branch must address its dysfunctional activities that inhibit 

C;fforts toward this end. The White House must lead. My recommendation is to place 

the re-instated EMP Commission permanent(r umler a White House Secretariat with 

direct access to the President, with a mandate to resolve the interagency conflicts of 

interest and programmatic activities-especially among DoD, DHS and DOE. Initially, 

8 
101 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Ambassador Henry F. Cooper, Ph.D. 

I would urge that Congress seek an early assessment of the viability of the nation's 

critical national infrastructure and associated regulatory operations, with spec(fic 

recommendations to the President and Congress for appropriate improvements. 

• Congressional initiatives could provide important incentives to encourage significant 

improvement in the various programs that must be conducted by the Executive Branch. 

Among them, I would encourage ways to incentivize local and state initiatives to work 

closely with the nation's several thousand electric utility companies and CoOps to 

assure electricity flows from the major electric power companies to key local, city and 

county key infrastructure, e.g, water-wastewater i!~frastructure that is key to hospitals, 

businesses, citizens, etc. 

• Finally, local leadership and active involvement of all our citizens is key to success. I 

can think of no more effective means to reach that goal than to work through the 

National Guard as the vehicle by which our State Adjutant Generals can achieve an 

effective national arrangement. At the end of the day, success will require a more 

effective alliance between the Departments of Defense and Homeland Security. And 

the National Guard should be challenged to help achieve that alliance. Congressional 

encouragement toward that end could be most helpful in resolving current "roles and 

missions" gaps. Hopefully, our Lake Wylie Pilot Study will provide a template that 

other states and the federal govemment can exploit in working toward that end. 

9 
102 

Responses to Questions for the Record 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

CAITLIN DURKOVICH 

Director, Toffler Associates 

Former Assistant Secretary, Infrastructure Protection, 

National Programs and Protection Directorate 

Department of Homeland Security 

Submitted to the 

SENATE ENERGY & NATURAL RESOURCES COMMITTEE 

Question 1: Much attention is focused on how to protect energy infrastructure, and particularly 

the electric grid, ti·om a high-altitude EMP or HEMP- burst due to its potential wide-spread 

impact. Given that a localized EMP burst is more powerfiii than a HEMP burst, would the same 

hardening technologies that are deployed for a HEMP burst successfully guard against a 

localized EMP attack? 

Industry and government are wm·king hand in hand to better understand the impacts of 

localized and high-altitude ElYII's. The work that Electric l'owcr Research Institute is 

conducting is critical to understanding how transformers, protective relays, SCADA, 

control cables would be affected by these types of bursts. This critical modeling can help 

inform where investments in shielding and other hardening approaches will have the 

maximum value. 

Question 2: One of the keys to a successful public-private partnership is trust and the 

willingness to share information. I am concerned. however, that there is a lack of trust by 

industry with the government- and for good reason. The December 2016 episode with 

Burlington Electric in Vermont is a perfect example. As I understand it, Burlington noticed an 

alert about a suspicious JP address that bad connected to one of their computers and responded to 

that alert by dutifully reporting that fact to the government. The same day that they reported the 

alert, however, the Washington Post somehow learned about it and reported that Russian hackers 

had infiltrated the United States' electric grid. Later follow-up would show that the IP address 

was not necessarily linked to Russia and there was not malicious activity, but the damage to trust 

had been done. How do we restore and build trust between the private sector and government so 

that this type of information can be freely shared without concern about it becoming a media 

spectacle? 
103 

The December 2016 Burlington Electric episode was an unfortunate episode in a longstanding and evolving trusted partnership between government and industry. That 

partnership is built on a foundation of safeguarding information and is leveraged daily to 

freely share physical and cyber vulnerabilities between government and industry. Congress 

provided government with authorities such as the Protected Infrastructure Information 

(PCII) Program under the Critical Infrastructure Information (CII) Act of 2002, which 

protects private sector infrastructure information voluntarily shared with the government 

for the purposes of homeland security and has established uniform procedures on the 

receipt, validation, handling, storage, marking, and use of voluntarily submitted critical 

infrastructure information. As the former senior official in charge of the PCII program, 

the protection of sensitive vulnerability information is taken very seriously and remains the 

foundation for information sharing activities between government and industry. The 

program has been enormously successfully and is currently in the early stages of the rule 

making process to modernize a rule that was drafted over 11 years ago. 

That trnst is also sustained through the Critical Infrastrncture Partnership Advisory 

Council (CIPAC), which aligns with the National Infrastructure Protection Plan (NIPP) 

2013: Partnering for Critical Infrastructure Security and Resilience. Specifically, CIPAC 

facilitates confidential interaction between government and representatives from the 

community of critical infrastructure owners and most notably through regular meetings 

between senior government and indsutry representatives to discnss sensitive topics. The 

enduring natnre of these meetings should give you confidence of the trnst that exists 

between the private sector and government and the fact that information is often freely 

shared without becoming a media spectacle. 

Question 3: You testified that HEMP threat vectors can originate from a missile; a satellite 

asset; or a "relatively low-cost balloon-borne vehicle." Please elaborate on the possibility of a 

balloon-borne vehicle to launch an EMP strike. Do you agree then with Ambassador Cooper's 

assert that "low-yield 'Super' EMP weapons" are a viable threat? 

My answer to this question is informed by classified intelligence and briefings and as such I 

can only provide a partial response. I believe the threat of"low-yield 'Super' EMP 

weapons" is very low likelihood. 

Question 4: Are there military applications to address HEMP or other EMP-related events that 

are not being made available to civilians? If so, how do we !itt that barrier? 

This is a question best answered by industry. There are utilities that arc testing EMP/GMD 

shielding and other hardening approaches. I do uot know if this includes military 

applications but if it does not, the best way to lift that barrier is to bring the stakeholders to 

the table to discnss options. 

Durkovich QFR Responses 2 
104 

Question from Senator Debbie Stabenow 

Question: During today's testimony, we heard that EMPs are a threat to our national security. 

However, the range of impacts appear vast, fi·om naturally occurring events causing grid 

disruptions, up to- and including- the aftermath of a high altitude nuclear detonation. 

This Committee has held several hearings in this and previous congresses on the threats facing 

our electric grid and critical energy infrastructure. From your perspective, how does the threat 

posed from EMPs compare to other vulnerabilities such as cybcr-attacks? 

There is no doubt we live in a dangerous world. State and non-state actors, insiders, and 

promulgators of disinformatiou arc growing in kind aud consequence. Bontcrs no longer 

protect us- whether our shores or the fences and network.~ of our organizations. \Ve have 

built a complex t:cosyst~:m where a disruption in one node can ripple at~ross the system and 

where threats are not bounded to one sector or industry. Nor can we protect against every 

threat and secure every building, system, and network. Our country is too big, our 

infrastructure is too complex, the cost too expensive, and the outcome would alter our wa~· 

of life. 

This environment is the basis for government and private sector participants in the critical 

infrastructure community working together to prioritize and manage risks to achieve 

security and resilience outcomes. Thin I< of a matrix where the x andy axis arc likelihood 

and consequence respectively. 

A denial of service attacl< is highly probable but the impact is minimal to operations 

Most natural disasters arc high likelihood and low consequence- Supcrstorm Sandy 

or a 9.0 Cascadia subduction zone event arc exceptions and flip -low likelihood, 

high consequence 

A GMD of the likes of the 1859 Carrington event we are beyond that 100 year 

window so I would say more likely and certainly high consequence 

A cybcr attack against industrial control systems. Lower probability than a DOS 

although increasing, and certainly higher impact. You only need to look at the 

December 2015 attack on the Ukrainian power grid. 

Thct·c are half a dozen mot·e risks on that matrix including an HEMP- we place it at a very 

low probability but very high consequence. 

Durkovich QFR Responses 3 
105 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Robin Manning 

Questions from Chairman Lisa Murkowski 

Question 1: In your written testimony, you mention that all three components of a HEMP event 

- E l, E2, and E3, are being evaluated. The effects ofE2 are fairly well known given its 

similarity to a lightning strike. Studies have been done, or are underway to individually look at 

E I and E3. Are there any studies that look at the cumulative effect of these three components? 

Would infrastructure react differently to an E2 blast after being hit by El. or an E3 after being hit 

by El and E2? 

The question posed is ultimately one that we are attempting to answer with our current research 

effort. We are unaware of any studies to date that have been conducted to evaluate the 

cumulative effect of all three components, El, E2 and E3. We are aware of at least one effort, in 

addition to the EPR! project, that is currently attempting to evaluate the cumulative effects of all 

three components. However, there are significant research gaps with regards to equipment 

vulnerability and modeling which makes performing such assessments extremely difficult. 

Current research efforts at EPRI are aimed at developing the capability to evaluate the combined 

effects of all three components. 

lt is certainly possible that infrastructure could react differently to E2 or E3 following El, but 

current research has not progressed to the point where we can provide a definitive answer. 

Results from the research described previously, once they are available, will be used to inform 

the potential impacts and address these important questions. 

Question 2: Mr. Manning, in your written testimony, you suggest that the E3 component of an 

EMP is similar to a severe GMD event. Could you please explain your reasoning on this matter? 

The interaction of the Earth's magnetic field in both a nuclear explosion and solar flares 

generates a similar result on the electric grid. Both induce very low ti·equency (quasi-de) 

currents in the grid which appear very much like a direct current flow superimposed in the 

alternating current grid. These currents are called gcomagnetically induced currents, or GIC. 

While the effect is similar, the magnitude and duration are very different. GIC currents arc much 

larger following a nuclear event than GIC currents resulting from a geomagnetic disturbance 

(GMD) event. However, the GIC resulting from a nuclear detonation is relatively short duration, 

rising and falling in a matter of minutes, whereas, solar induced GIC can last for days with 

several periods of peak activity. In both cases, the flow ofGIC in transformer windings results 

in half-cycle saturation, potentially leading to voltage collapse and additional hotspot heating in 

bulk-power transformers which can cause physical damage in some cases. Additionally, halfcycle saturation causes the transformers to inject harmonic currents into the grid which can result 

in additional impacts by causing equipment designed to supply reactive power to trip off-line; 

thus, fi.trther exacerbating voltage issues in the grid. Mitigation strategies, e.g. neutral blocking 

devices, etc., to reduce the impact ofG!C currents are effective against both E3 and GMD 

induced currents. Additionally, utilities can monitor GIC in real time, and make informed 
106 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Robin Manning 

decisions about the impacts ofGIC because of the lower energy and longer timeframe. This is 

not true for GlC induced by E3. which occurs too rapidly for human intervention. 

Question 3: Much attention is focused on how to protect energy infrastructure, and particularly 

the electric grid, from a high-altitude EMP or HEMP- burst due to its potential wide-spread 

impact. Given that a localized EM!' burst is more powerful than a HEMP burst, would the same 

hardening technologies that are deployed for a HEMP burst successfully guard against a 

localized EMP attack? 

Localized EMP is designed to emit a high-energy pulse that emulates the E I signature of an 

HEMP. Mitigation measures designed to offer El HEMP protection, e.g. MIL-STD-188-125-1, 

would also provide a level of protection against localized EMP. However, because some 

weapons that may be used in a localized EMP attack generate significant energy levels at 

trequencies higher than those currently specified in MIL-STD-188-125-1, it is not clear whether 

the level of protection would be the same as that provided for HEMP (E I). 

Question 4: Thank you not only for your testimony today but for your willingness to be a 

witness last year before this Committee's Subcommittee on Energy. Comparing your testimony 

from last July with your testimony for this hearing, it appears to me that EPRI specifically and 

industry generally has stepped up activity over the last year to address EMP and related issues 

and challenges. Can you summarize the trajectory ofEPRI, industry, and related DOE efforts 

over the last year and where you expect to see these efforts moving over the next 2 or three 

years? Where would you expect us to be in three years' time on this issue compared with today? 

Is there any prudent way to move more quickly? 

Many factors have brought EPRI, DOE and the industry together around the EMP issue over the 

past year, including growing awareness ofthe EMP threat and a deeper understanding ofthc 

potential consequences of an EMP attack. Evidenced by the broad industry participation, the 

EPRI EMP project is meeting a relevant need. This need also happens to align very well with 

the DOE push to take action around protecting the nation • s infrastructure. 

EPRI's research project is on-track with the 3-year plan. The impacts of E3 on bulk transformers 

was selected as the foundational threat because it held the highest potential for replacement 

challenges. Now that this component is complete, the project is moving to the voltage collapse 

issue from E3, the equipment and controls risk from E I, and the aggregate risk from all three 

energy waves (E 1, E2 and E3) together. The voltage collapse results are expected late summer. 

and initial El results by year-end, 2017. Aggregation of all risks will be done last with the 

research project's scheduled completion in spring, 2019. Additionally, we are evaluating the 

potential for developing cost-effective mitigation options so that reliability can be maintained 

without utilizing more extreme approaches, e.g. MIL-STD-188-125-1. 

2 
107 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Robin Manning 

Project speed continues to be a challenge. Everyone involved would like to see the work 

completed as fast as possible. However, while a great of deal work has been done on EMP, very 

little has been directly applied to the electric utility infrastructure. Much of this work is first 

time, groundbreaking work. Even so, it is not the work itself that drives the timeline- it is the 

collaborative transformation. As important as the technical learning is building an understanding 

and communication of the resulting information. As this project advances, so too advances the 

knowledge base of the nation's electric grid owners and operators. While this may seem like a 

long time to wait, it is remarkably quick compared to our progress to date. 

When this research project is finished in April, 2019, it will conclude with a broad understanding 

of the threat, mitigation and recovery actions around EMP. We anticipate that utilities and 

stakeholders will have concrete options for balancing the EMP threat against others. 

Question 5: EMP models are only as good as the data inputs provided. The United States has 

not tested any nuclear weapons since 1992, and no atmospheric tests since the Test Ban Treaty of 

1963. My understanding is that many of our weapon designs have required post-deployment 

tests to resolve problems- and those problems were discovered only because of ongoing nuclear 

tests at the time. In each case, the weapons were thought to be reliable and thoroughly tested. 

How confident are you that the data being inputted into the models with regard to the EMP 

effects of a nuclear weapon detonation is accurate- particularly since we have not conducted an 

atmospheric test since 1962? 

a. Since most of the data is controlled by the Department of Defense and the 

National Labs, does the private sector have access to the data needed to accurately 

model the potential EMP impact and effect of a nuclear explosion? 

b. My understanding is that most HEMP models are based on a one dimensional, 

spherically symmetric model, neglect scattering effects, and are unable to model 

2- and 3-D effects. There is also no high-fidelity model that predicts EMP from 

detonations from 5 kilometers to 20 kilometers above the Earth's surface. Given 

these shortfalls, how confident are you in the accuracy of current EMP models? 

Question from Senator Debbie Stabenow 

Ouestion: During today's testimony, we heard that EMPs are a threat to our national security. 

However, the range of impacts appear vast, from naturally occurring events causing grid 

disruptions, up to- and including- the aftermath of a high altitude nuclear detonation. 

3 
108 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Robin Manning 

This Committee has held several hearings in this and previous congresses on the threats facing 

our electric grid and critical energy infrastructure. From your perspective, how does the threat 

posed from EMPs compare to other vulnerabilities such as cyber-attacks? 

We would refer you to the Intelligence Community and the Department of Energy for additional 

information regarding how the two threats compare. 

Utilities often usc a threat assessment process to balance investments. This is an effective way to 

gauge one risk verses another. This approach requires an assessment of both the probability of 

an event, and a consequence should the event occur. EMP probability is very difficult to assess, 

and most utilities will place this in an unlikely, but possible category. However, the 

consequences of even an unlikely event can be extremely severe. Contrast this with cyberattacks which are now occurring daily, but largely with less severe consequences. An effective 

strategy would be to invest in reducing both the probability and the consequences of cyberattacks, while focusing exclusively on reducing consequences of an EMP attack. This is exactly 

why utilities are interested in the EPRI project to inform the discussion around reducing EMP 

consequences. In any case, both require attention, albeit via difterent approaches. It is not a 

matter of which threat is more or less critical, it is a matter of what strategies can be deployed to 

lower the overall risk, including all threats evaluated. 

4 
109 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017, Hearing: The Threat Posed by Electromagnetic Pulse and 

Policy Options to Protect Energy Infrastructure and to 

Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Kevin Wailes 

Questions from Chairman Lisa Murkowski 

Question 1: Much attention is focused on how to protect energy infrastructure, and particularly 

the electric grid, from a high-altitude EMP or HEMP burst due to its potential wide-spread 

impact. Given that a localized EMP burst is more powerful than a HEMP burst, would the same 

hardening technologies that are deployed for a HEMP burst successfully guard against a 

localized EMP attack? 

The impact of an EMP caused by a directed energy weapon depends on the size of' the weapon 

used Given that the damage resultingfromthis (vpe ofEMP would be localized, hardening 

technologies designed to protect against the widespread impact of a HEMP event may not 

provide adequate protection. However. there is a great deal ofsvstem redundancy built into !he 

grid !hat would mitigate the impac/ ol an individual direc!ed energy weapon. To cause 

significan/ damage Ia the electric grid, dozens of' directed energy weapons would need to be 

built, deployed, and detonated in a coordinated attack. tv! ore effective protections for these types 

of'Ek!Ps are physical protection measures, such as limiting proximity and control!ing access to 

substations and comrol centers. 

Question 2: One of the keys to a successful public-private partnership is trust and the 

willingness to share information. I am concerned, however, that there is a lack of trust by 

industry with the government and for good reason. The December 2016 episode with 

Burlington Electric in Vermont is a perfect example. As I understand it, Burlington noticed an 

alert about a suspicious IP address that had connected to one of their computers and responded to 

that alert by dutifully reporting that fact to the government. The same day that they reported the 

alert, however, the Washington Post somehow learned about it and reported that Russian hackers 

had intlltrated the United States' electric grid. Later follow-up would show that the IP address 

was not necessarily linked to Russia and there was not malicious activity, but the damage to trust 

had been done. How do we restore and build trust between the private sector and government so 

that this type of information can be freely shared without concern about it becoming a media 

spectacle? 

Trust is the jhundation on which sharing information between industry and govern men! is 

dependent. This is why the electric industry thought it so important jbr the Cybersecurity Act ol 

2015 and the energy provisions of' the 2015 FAST Act to include language to ensure thai shared 

information be kept class!fled and not allowed to be used for regulatory purposes. 

You are correct in your characterization of this unfiirtunate event. The best W(!Y to restore and 

build trust between the private sector and government is to ensure that a leak like this does not 

occur again. While disappointed andfi'ustrated with !he wav this incident was handled, to its 

great credit, Burlington Electric publicly stated that it would no! pull back from sharing 

infimnation with the federal government because it recognizes that protecting !he grid against 

cyber threats, by its nature, requires a strong government-industry parlnership. As I commented 
110 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017, Hearing: The Threat Posed by Electromagnetic Pnlse and 

Policy Options to Protect Energy Infrastructnrc and to 

Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Kevin Wailes 

during the hearing. this was a significant learning experiencefi!r both industry and our 

government partners. I would also add that processes like the DOE-OE417 reporting 

requirements need to he revised so utilities can share information anonymously 

Question 3: Your written testimony provides, and I quote "there are concerns that installing 

'protective devices' in some areas of the bulk power system could unintentionally cause 

problems in other areas. Further research and testing of these devices is needed. Even assuming 

that every conceivable blocking device were installed to protect every inch of the electric grid 

and caused no problems, power supplies still would likely be subject to disruption from other 

collateral impacts due to a HEMP event." Given that, what do you think is the most prudent way 

for industry and government to improve our efforts to ride through an EMP attack? 

Industry and government need more scientific information on the potential impact of a HEMP 

and effective mitigation techniques. As I described in my testimony, the multi-year research 

effort being led by the Electric Power Research Institute (EPR!) is an attempt to model the 

effects of a HEMP on the grid using highly technical data. TYe must have a be Iter understanding 

oft he science o{how a HEA1P would affect the grid before mandating any particular devices or 

strategies. To move forward wirhoutthis infiJrmation would at best he wasteful, and at worst, be 

harmfid due to the possibility of unintended consequences. 

I also must again stress that the electric sector faces a broad threat landscape. We understand 

that we cannot protect all assets completelyfi'om all threats, and instead must manage risk. A 

HEMP event is categorized as a "high impact, low probability" threat. It would have a 

potentially catastrophic impact on society that would impact all critical infrastructure sectors. 

An attack of this magnitude would he an act of war or terrorism. As such, the federal government 

is responsible for preventing HEMPs as a matter of national security. 

Question 4: Your written testimony recommends that the recently-reconstituted EMP 

Commission work more closely with, and I am quoting, "owners and operators of critical 

infrastructure, EPRI, ESCC. NERC. and the E-TSAC as the Commission executes its mission to 

assess the vulnerability of the electric grid to EMPs and to develop recommended policy actions. 

Combining the unique backgrounds of the EMP Commission with the knowledge of experts in 

grid engineering and operations would produce a more meaningful and informed product.'' 

Please elaborate. 

The electric grid is a very complex yet resilient integrated network ofgenerators, transmission 

lines, and control :,ystems. Modeling how electricityf/ows thorough this system and how it will 

react to the loss of a generator or loss of multiple transmission lines is a complex process that is 

more art than science. The electric industry is comprised of experts in engineering and 

operations; they are not experts in nuclear weapons. The EMF Commission is largely comprised 

of those with expertise in nuclear weapons; they are not experts in modeling the complex grid 

2 
111 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017, Hearing: The Threat Posed by Electromagnetic Pulse and 

Policy Options to Protect Energy Infrastructure and to 

Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Kevin Wailes 

operations during extreme events. Neither side has all the expertise or answers. Congress should 

direct the EMF Commission to engage in meaningful consultation with the electric industry 

b~fore releasing ils next report. 

Question 5: EMP models are only as good as the data inputs provided. The United States has 

not tested any nuclear weapons since 1992, and no atmospheric tests since the Test Ban Treaty of 

1963. My understanding is that many of our weapon designs have required post-deployment 

tests to resolve problems- and those problems were discovered only because of ongoing nuclear 

tests at the time. In each case, the weapons were thought to be reliable and thoroughly tested. 

How confident are you that the data being inputted into the models with regard to the EMP 

dfects of a nuclear weapon detonation is accurate- particularly since we have not conducted an 

atmospheric test since 1962? 

I do not have the scientific or defense background necessary to answer this question. As such, I 

must defer to the exlraordinari/y qualzfied researchers a/ the national labs and EPRJ, in which I 

have fiill:faith. 

a. Since most of the data is controlled by the Department of Defense and the 

National Labs, does the private sector have access to the data needed to accurately 

model the potential EMP impact and effect of a nuclear explosion? 

Yes, the unclassified HEMP information provided in a number of reports and 

industry standards can adequately inform the research activities being conducted 

in the private sector. However, ensuring electricity sector engineers and DOE 

experts are privy to the classified research from DOD weapons programs is 

integral to ensuring critical infrastructure operators have the il?formation they 

need to unde1~vtand and mitigate threats posed by HEiv!P. 

b. My understanding is that most HEMP models are based on a one dimensional, 

spherically symmetric model, neglect scattering effects, and are unable to model 

2- and 3-D effects. There is also no high-fidelity model that predicts EMP from 

detonations from 5 kilometers to 20 kilometers above the Earth's surface. Given 

these shortfalls, how confident arc you in the accuracy of current EMP models? 

Again, J do not have the scientific or defense background necessmy to answer this 

question and, as such, must defer the national labs and EPRJ. However, the 

modeling of the electric grid's reaction to a HEMP event requires different 

expertise from those who model the electromagnetic waves from a HEMP. 

3 
112 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017, Hearing: The Threat Posed by Electromagnetic Pulse and 

Policy Options to Protect Energy Infrastructure and to 

Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Kevin Wailes 

Question 6: In your written testimony you mention the Schweitzer report and its conclusion that 

''existing IEEE substation design standards are sufficient to protect intelligent electronic devices 

from HEMP." How many of the substations in the U.S. adhere to these design standards? 

Although I cannot cite a specific number, the majority of the substations in the United States 

adhere to IEEE standards; the larger and more critical the substation, the more likely it follows 

the standards. They key point to note here is that the industry has formulated standards on its 

own. 

Question from Senator Debbie Stabenow 

Question: During today's testimony, we heard that EMPs are a threat to our national security. 

However, the range of impacts appear vast, from naturally occurring events causing grid 

disruptions, up to- and including- the aftermath of a high altitude nuclear detonation. 

This Committee has held several hearings in this and previous congresses on the threats facing 

our electric grid and critical energy infrastructure. From your perspective, how does the threat 

posed from EMPs compare to other vulnerabilities such as cyber-attacks? 

A HEMP event is categorized as a "high impact, low probability" threat. I believe a cyberattack aimed at disrupting electric se111ice would be a relatively cheaper and easier weapon to 

deploy than finding the needed nuclear materials to assemble and deploy a sophisticated 

weapon. So clearly we must place more effort and resources on mitigating the highest and most 

probable risks. I have included a "threatland~cape" visual produced by the North American 

Reliability Corporation (NERC) on the next page for your reference. 

4 
113 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017, Hearing: The Threat Posed by Electromagnetic Pulse and 

Policy Options to Protect Energy Infrastructure and to 

Improve Capabilities for Adequate System Restoration 

Questions for the Record Submitted to Mr. Kevin Wailes 
114 

U.S. Senate Committee on Energy and Natural Resources 

May 4, 2017 Hearing: The Threat Posed by Electromagnetic Pulse 

and Policy Options to Protect Energy Infrastructure 

and to Improve Capabilities for Adequate System Restoration 

Responses Submitted by Dr. David Brumley at the 

Request of the Honorable Newt Gingrich 

Question from Chairman Lisa Murkowski 

Question: One of the keys to a successful public-private partnership is trust and the willingness 

to share information. 1 am concerned. however, that there is a lack of trust by industry with the 

government- and for good reason. The December 2016 episode with Burlington Electric in 

Vermont is a perfect example. As I understand it, Burlington noticed an alert about a suspicious 

IP address that had connected to one of their computers and responded to that alert by dutifully 

reporting that fact to the government. The same day that they reported the alert, however, the 

Washington Post somehow learned about it and reported that Russian hackers had infiltrated the 

United States' electric grid. Later follow-up would show that the IP address was not necessarily 

linked to Russia and there was not malicious activity, but the damage to trust had been done. 

How do we restore and build trust between the private sector and government so that this type of 

information can be freely shared without concern about it becoming a media spectacle? 

Response to Part I: "How do we restore und build trust between the private sector and 

govemment": Plainly speaking, there is no upside to reporting, only potential downside. 

No upside: Typically the government has no ability to stop an intrusion during an event, and has 

little ability to find attackers after an event. It's like reporting to the cops your car window was 

broken and your radio stolen: they will take note of it, but don't expect to get anything back. 

The potential downside: The company risks when reporting include at least: 

- Potential liability issues to their customers 

-Reputation loss if the information becomes public 

Overall, I would agree with the senators statement: "One of the keys to a successful publicprivate partnership is trust and the willingness to share information." However, I believe a much 

more significant factor in a successful public-private partnership is value in both sides. 

In the car analogy, the value to a citizen to reporting to the police is often such a report is needed 

for insurance purposes, while the benefit to the police is situational awareness. 

Response to Part 2: "This type ~~(information cun be freely slwred without concern about it 

becoming a media spectacle?" I do not know the specifics of how the Washington Post became 

aware of the incident, and therefore cannot comment on the specifics. 

In general, I do believe that companies should be able to report security incidents to the US 

government without fear of it being leaked. I do believe there arc many such places one could 

report an incident, including US-CERT and the FBI Infraguard (!lJ!pcdiiiJV.w.infi·a!lclflLQJ:g,:). 

Both provide strong privacy to the reporter. 

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