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Gatekeeping at the FERC – NERC Physical Security Joint Technical Conference

On August 10, 2023, the North American Electric Reliability Corporation (NERC) hosted a joint conference with the Federal Energy Regulatory Commission (FERC) to “discuss physical security of the bulk power system.”

Previous readers may know that I have many concerns about current physical security standards and practices for the electric energy grid. I hoped to attend the conference to share my questions, concerns, and recommendations with FERC and NERC officials. Unfortunately, I was unable to do so.

In this article, I’ll share more about my experience at the conference and recommendations that I would have shared, if given the chance. Follow along to learn more.

My Inspiration to Attend

Earlier this year, on April 14, 2023, NERC Associate General Counsel Shamai Elstein directed a letter to FERC Secretary Kimberly D. Bose, entitled "Evaluation of the Physical Security Reliability Standard and Physical Security Attacks to the Bulk-Power System.” After reviewing this document, I felt compelled to submit a letter to Secretary Bose and General Counsel outlining my observation that electric utilities must do more to address the vulnerability to physical attack of the electric energy grid.

After numerous follow-ups, NERC Associate General Counsel Elstein replied that if I had concerns, I should attend the FERC/NERC Physical Security Technical Conference in Atlanta.

I registered for the conference, bought my airline ticket, and headed to Atlanta, prepared to ask NERC and FERC officials a variety of questions and share my perspective. I had hoped that subject matter experts would be given the opportunity to describe innovations that will increase grid resiliency and redundancy.

Dashed Expectations at the FERC and NERC Conference

My expectations were dashed as soon as I entered the North Tower Conference Room. Approximately half of the seats were assigned to NERC dignitaries, FERC participants, and panelists.

The first announcements were that panelists would be asked prescreened questions and that only FERC VIPs could ask follow-up questions. Questions or comments were not permitted from regular conference attendees like me.

Innovation Assassins Lurk within FERC and NERC

As an executive who routinely provides expert witness testimony and directs corrective actions, I’ve learned to expect that companies frequently nominate panelists who effectively present the “politically correct” point of view.

I’ve also learned to categorize people as innovation leaders, supporters, resters, and assassins. The attitudes of these four categories of people are outlined in Figure 1.

Figure 1 shows the innovation energy-attitude matrix used to identify innovation leaders, supporters, resters, and assassins.

Figure 1 shows the innovation energy-attitude matrix used to identify innovation leaders, supporters, resters, and assassins.

Of the twenty panelists at this conference, I categorized three as innovation leaders, eight as supporters, one as a rester, and eight as assassins. While innovation leaders focus their energy on progressing to the next generation electric energy grid, innovation assassins are subject matter experts whose goal is to assure that the status quo is maintained by stifling innovation.

When only three innovation leaders are present, and eight innovation assassins are vocal panelists, little time is given to hearing innovative ideas. The panel effectively projected their bias that, given financial constraints, CIP-014-3 is very good with little need for change.

Feedback for FERC and NERC on Grid Physical Security

As an electrical engineering professional who has worked in energy control centers, nuclear power plants, substations, engineering offices, and engineering firms, I have thought a lot about improvements to physical security for the electric energy grid.

I was prepared to offer the following recommendations during the conference:

  1. The models that electric utilities and regional transmission operators utilize to evaluate the robustness of the electric energy grid need to be updated to include air conditioners, distributed renewable energy sources, anticipated electric vehicle charging stations, and more.

  2. Faults, short circuits, are “electric sinkholes” – the area of the voltage depression, which can be 1,000 square miles or 10,000 square miles, is a function of transmission system ­­parameters.

Figure 2 is an illustration of an “Electric Sinkhole.”

Figure 2 is an illustration of an “Electric Sinkhole.”

3. Recovery models for voltage depressions caused by saboteurs must be based on voltage profiles that are expected after a three-phase fault persists for 250 milliseconds.

4. In substations equipped with 230 KV, 345 KV, 500 KV or 765 KV circuit breakers, every battery room and control house must be designated as vital areas with enhanced security measures to detect and deter intruders, saboteurs, and disgruntled employees.

5. In every substation equipped with 230 KV, 345 KV, 500 KV or 765 KV circuit breakers, every oil or gas filled component must be concealed from view from outside the fence.

6. Staged fault tests must be conducted to verify that models are representative of actual performance.

7. Robust security can be provided at existing substations at less than 1% of the cost to replace components inside the substation fence.

8. Substations must be designed so that when a single component is sabotaged, only one facility is compromised. This includes batteries, control houses, cable trays, and cable trenches where multiple components are intermingled.

In an upcoming series, I will address each of these recommendations in more detail. To learn more about Prescient’s recommended enhancements to grid physical security and our power system security assessments, check out our website. Or contact me with your specific questions.

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