Statement of
Richard J. Campbell
Specialist in Energy Policy
Before
Committee on Transportation and Infrastructure
Subcommittee on Economic Development, Public Buildings and
Emergency Management
U.S. House of Representatives
Hearing on
“Blackout! Are We Prepared to Manage the
Aftermath of a Cyber-Attack or Other Failure
of the Electrical Grid?”
April 14, 2016
Congressional Research Service
https://crsreports.congress.gov
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Good Morning Chairman, Ranking Member, and Members of the Subcommittee. My name is Richard
Campbell. I am a Specialist in Energy Policy for the Congressional Research Service (CRS). On behalf of
CRS, I would like to thank the Committee for inviting me to testify here today.
My testimony will provide background on the possible consequences of a failure of the electric grid, the
roles and responsibilities of the respective parties, and some of the objective challenges in the recovery
efforts. I should note that CRS does not advocate policy, or take a position on specific legislation.
Potential Failure of the Electric Grid
The electric power grid in the United States comprises all of the power plants generating electricity,
together with the transmission and distribution lines and systems which bring power to end-use
customers. The grid also connects the many publicly and privately owned electric utility and other
wholesale power companies in different states and regions of the United States.1 However, with changes
in federal law,2 regulatory changes, and modernization of the electric power infrastructure as drivers, the
grid is changing from a largely patchwork system built to serve the needs of individual electric utility
companies to essentially a national interconnected system, accommodating massive transfers of electrical
energy among regions of the United States.
Electricity generation is vital to the commerce and daily functioning of United States. While the U.S.
electric grid has operated historically with a high level of reliability, the various parts of the electric power
system are all vulnerable to failure due to natural, operational, or manmade events.
Electric power is generated and sent over transmission lines to substations which reduce the voltage levels
for distribution to end-use customers. The cables carrying electric power to customers generally exist in
an exterior or “above ground” environment largely exposed to the elements. As such, power outages can
result from floods or seasonal storms which often combine the furies of wind, rain, snow, or ice. The more
severe weather events can damage electric power transmission and distribution infrastructure as trees or
overhanging branches fall on electricity lines. Most failures of the grid occur in local distribution systems
rather than bulk power transmission systems, as the rights-of-way for transmission lines are wider, and are
cleared to prevent damage from trees. The cost of weather-related power outages may range from $25
billion to $55 billion annually.3
Other impairment or failure of the grid can potentially result from attacks, terrorism, or even extremes of
space weather. For example, a nuclear weapon exploded at a high altitude over the United States would
cause an electromagnetic pulse which could destroy power transformers and other critical components. 4
Similarly, a severe solar storm could have damaging impacts on power transformers. Sunspots send
plasma from coronal mass ejections into space, which could interact with the Earth’s magnetic field
causing ground induced currents powerful enough to overload transformers. The last major solar flare

1 As of 2013, there were 189 investor-owned electric utilities, 2,013 publicly-owned electric utilities, 887 consumer-owned rural
electric cooperatives, and nine federal electric utilities. American Public Power Association, U.S. Electric Utility Industry
Statistics, 2015, http://www.publicpower.org/files/PDFs/USElectricUtilityIndustryStatistics.pdf.
2 Key legislation includes the Public Utility Regulatory Policies Act of 1978 (P.L. 95-617, as amended), the Energy Policy Act of
1992 (P.L. 102-486), the Energy Policy Act of 2005 (P.L.109-58), and the Energy Independence and Security Act of 2007 (P.L.
110–140).
3 “Power outages can impact electricity consumers primarily through property loss and business disruption. This can result in lost
orders, and damage to perishable goods and inventories for businesses. Power outages can critically affect manufacturing
operations mainly through downtime as workers are idled, and potentially damage equipment and production processes.” CRS
Report R42696, Weather-Related Power Outages and Electric System Resiliency, by Richard J. Campbell.
4 See Congressional Distribution Memorandum, Space Weather and EMP threats to the Grid, 2015, by Richard Campbell.
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eruption in 1989 caused blackouts in the Canadian province of Quebec. Even greater solar storms occur in
cycles of approximately 100 years, with major events being recorded in 1859 and 1921.5
Much of the infrastructure which serves the U.S. power grid is aging. As of 2009, the average age of
power plants was over 30 years, with most of these facilities having a life expectancy of 40 years.6
Electric transmission and distribution system components are similarly aging, with power transformers
averaging over 40 years of age,7 and 70% of transmission lines being 25 years old or older,8 as of 2007.
As the grid is modernized, new intelligent technologies utilizing two-way communications and other
digital capabilities, are being incorporated with Internet connectivity. The “Smart Grid” refers to this
evolving electric power network.9 While these advances may improve the efficiency and performance of
the grid, they also increase its vulnerability to cyberattacks launched from the Internet. The potential for a
major disruption or widespread damage to the nation’s power system from a large-scale cyberattack has
increased focus on the cybersecurity of the grid. Modernization of many industrial control systems (ICS),
in particular, Supervisory Control and Data Acquisition (SCADA) systems used by electric utilities, have
also resulted in connections to the Internet.10 The increasing frequency of cyber intrusions on ICS is a
concern to the electric power sector. Power production and flows on the grid are controlled remotely by a
number of IC technologies. The National Security Agency reported that it has seen intrusions into IC
systems by entities with the apparent technical capability “to take down control systems that operate U.S.
power grids, water systems and other critical infrastructure.”11
Although there has not been a publicly-reported cybersecurity event or physical attack resulting in a large
scale power outage in the United States,12 the potential for such attacks to cause a wide scale, long lasting
outage cannot be dismissed. The first blackouts attributed to a cyberattack happened in the Ukraine in
December 2015.13 The power outages affected approximately 225,000 customers, and are said to have
originated from remote cyber intrusions at three regional electric power distribution companies. The
cyberattackers targeted industrial control and operating systems at multiple central and regional facilities.
The cyberattack also targeted other critical infrastructure,14 apparently in an attempt to impair recovery
efforts.

5 Ibid.
6 Massachusetts Institute of Technology, Retrofitting of Coal-Fired Power Plants for CO2 Emissions Reductions, March 23,
2009, http://web.mit.edu/mitei/docs/reports/meeting-report.pdf.
7 Thomas A. Prevost and David J. Woodcock, Transformer Fleet Health and Risk Assessment, Weidman Electrical Technology,
IEEE PES Transformers Committee Tutorial, March 13, 2007, http://grouper.ieee.org/groups/transformers/info/S07/S07-
TR_LifeExtension.pdf.
8 K. Anderson, D. Furey, and K. Omar, Frayed Wires: U.S. Transmission System Shows its Age, Fitch Ratings, October 25, 2006.
9 In recognition of the need to deploy new technologies, Congress indicated its support for grid modernization in the Energy
Independence and Security Act of 2007 (EISA) (P.L. 110-140). Specifically, Section 1301 of the act states: “It is the policy of the
United States to support the modernization of the Nation’s electricity transmission and distribution system to maintain a reliable
and secure electricity infrastructure that can meet future demand growth ... which together characterize a Smart Grid.”
10 CRS Report R43989, Cybersecurity Issues for the Bulk Power System, by Richard J. Campbell. (Hereinafter, CIBS).
11 Peter Behr, Cyberattackers have penetrated U.S. infrastructure systems -- NSA Chief, Environment & Energy Daily, November
21, 2014, http://www.eenews.net/energywire/stories/1060009391.
12 Steve Reilly, Bracing for a big power grid attack: ‘One is too many’, USA Today, March 24, 2015,
http://www.usatoday.com/story/news/2015/03/24/power-grid-physical-and-cyber-attacks-concern-security-experts/24892471/.
13 DHS - Industrial Control Systems Cyber Emergency Response team, Cyber-Attack Against Ukrainian Critical Infrastructure,
Alert (IR-ALERT-H-16-056-01), February 25, 2016, https://ics-cert.us-cert.gov/alerts/IR-ALERT-H-16-056-01.
14 “In addition, three other organizations, some from other critical infrastructure sectors, were also intruded upon but did not
experience operational impacts.” Ibid.
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A report15 released by the National Research Council (NRC) in 2012 concluded that well-informed
terrorists could black out a large region of the country for weeks or even months.
An event of this magnitude and duration could lead to turmoil, widespread public fear and an image
of helplessness that would play directly into the hands of the terrorists. If such large extended
outages were to occur during times of extreme weather, they could also result in hundreds or even
thousands of deaths due to heat stress or extended exposure to extreme cold.
The largest power system disruptions experienced to date in the United States have caused high
economic impacts. Considering that a systematically designed and executed terrorist attack could
cause disruptions that were even more widespread and of longer duration, it is no stretch of the
imagination to think that such attacks could entail costs of hundreds of billions of dollars—that is,
perhaps as much as a few percent of the U.S. gross domestic product (GDP), which is currently
about $12.5 trillion.16
The NRC report further commented on the potential effects of a combined cyber and physical attack on
the grid.
If they could gain access, hackers could manipulate SCADA systems to disrupt the flow of
electricity, transmit erroneous signals to operators, block the flow of vital information, or disable
protective systems. Cyber attacks are unlikely to cause extended outages, but if well coordinated
they could magnify the damage of a physical attack. For example, a cascading outage would be
aggravated if operators did not get the information to learn that it had started, or if protective devices
were disabled.17
Similar conclusions were reached in a 2015 report from Cambridge University and Lloyds of London,
which theorized that a targeted cyberattack could leave 15 states and 93 million people from New York
City to Washington, D.C. without power. The scenario estimated the total impact to the U.S. economy at
between $243 billion and $1 trillion, resulting from “direct damage to assets and infrastructure, decline in
sales revenue to electricity supply companies, loss of sales revenue to business and disruption to the
supply chain.”18
The 2013 attack on the Metcalf substation in California further cast light on the physical vulnerabilities of
the grid. After someone broke into a nearby underground vault to cut telephone cables, snipers opened fire
on the substation, knocking out 17 large power transformers sending power to Silicon Valley. A blackout
was averted by rerouting power around the substation, and local power plants had to produce more
electricity. But it took the local utility 27 days to restore the substation. The Federal Energy Regulatory
Commission’s (FERC’s) chairman at the time (Jon Wellinghoff) reportedly said that “if [the attack] were
widely replicated across the country, it could take down the U.S. electric grid and black out much of the
country.”19
Recovery from a well-planned cyber and physical attack on the grid could be complicated by the cost and
vulnerability of critical components. While a physical attack on transmission towers to bring down power
lines could cause blackouts, the strategic destruction of a number of critical high-voltage transformers

15 National Academy of Sciences, Terrorism and the Electric Power Delivery System, 2012,
http://www.nap.edu/catalog/12050/terrorism-and-the-electric-power-delivery-system.
16 Ibid, page 1.
17 Ibid, page 2.
18 University of Cambridge Centre for Risk Studies and Lloyds of London, Business Blackout, The insurance implications of a
cyber attack on the US Power Grid, 2015,
https://www.lloyds.com/~/media/files/news%20and%20insight/risk%20insight/2015/business%20blackout/business%20blackout
20150708.pdf.
19 Rebecca Smith, Assault on California Power Station Raises Alarm on Potential for Terrorism, Wall Street Journal, February 5,
2014, http://www.wsj.com/articles/SB10001424052702304851104579359141941621778.
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could cause long-lasting power outages. These transformers are very large, and difficult to move. A large
scale attack may use up the limited inventory of spare units,20 and it may take months or even years to
build new units. The availability of other large components, such as high-voltage circuit breakers could
also hamper recovery efforts.21
Industry and Government Coordination on Recovery
Efforts
The electric utility industry generally prepares for power outages from weather-related events, and views
the potential for a major cybersecurity attack or similar event as a low probability risk. As such, the
industry seeks to balance grid security efforts and expenditures with the perceived risks. In the event of a
large power outage, electric utilities often call upon other utilities via their mutual assistance agreements22
(MAAs) to help restore services. MAAs can help to reduce the duration of weather-related outages by
bringing in outside resources to aid the recovery effort.
If an event is severe enough to be a federally-declared disaster,23 the Department of Homeland Security’s
(DHS’s) Federal Emergency Management Agency (FEMA) is empowered to provide federal assistance.
FEMA’s mission is to reduce the loss of life and property and protect communities nationwide from
all hazards, including natural disasters, acts of terrorism, and other man-made disasters. FEMA leads
and supports the nation in a risk-based, comprehensive emergency management system of
preparedness, protection, response, recovery and mitigation.24
FEMA can provide financial assistance to electric utilities to aid in disaster recovery efforts. In general,
FEMA will determine a utility’s eligibility, and “will cover at least 75 percent of the repair, restoration or
replacement costs for infrastructure owned by eligible applicants.”25
The electric power industry also works with the Departments of Energy and Homeland Security on a
number of cyber and physical security initiatives.26 The Electricity Sub-Sector Coordinating Council

20 The electric power industry has several programs for participating companies to share spare transformer equipment. For
example, “[the Edison Electric Institute’s Spare Transformer Equipment Program] requires participating utilities to maintain (or
acquire) a specific number of transformers up to 500 kV to be made available to other utilities in case of a critical substation
failure. Sharing of transformers is mandatory based on a binding contract subject to a ‘triggering event’—a coordinated act of
deliberate, documented terrorism resulting in the destruction or disabling of a transmission substation and the declaration of a
state of emergency by the President...[and in] 2012, NERC initiated its Spare Equipment Database program intended to serve as a
tool to ‘facilitate timely communications between those needing long-lead time equipment damaged in a [high impact, low
frequency] event and those equipment owners who may be able to share existing equipment being held as spares by their
organization.’” See CRS Report R43604, Physical Security of the U.S. Power Grid: High-Voltage Transformer Substations, by
Paul W. Parfomak.
21 NAS.
22 Edison Electric Institute, Understanding the Electric Power Industry’s Response and Restoration Process, May 2014,
http://www.eei.org/issuesandpolicy/electricreliability/mutualassistance/Documents/MA_101FINAL.pdf.
23 “[The] Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law 100-707, signed into law November 23,
1988; amended the Disaster Relief Act of 1974, Public Law 93-288. It created the system in place today by which a presidential
disaster declaration of an emergency triggers financial and physical assistance through the Federal Emergency Management
Agency (FEMA). The Act gives FEMA the responsibility for coordinating government-wide relief efforts.” See
http://www.fema.gov/about-agency.
24 Federal Emergency Management Agency, FEMA, FEMA B-653, July 2008, http://www.fema.gov/pdf/about/brochure.pdf.
25 Edison Electric Institute, Federal Disaster Assistance and Utilities, 2014,
http://www.eei.org/issuesandpolicy/RES/14Tab5.pdf.
26 See CIBS, page 16.
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(ESCC) is the principal liaison between the federal government and the electric power sector. It represents
the electricity sub-sector (as part of the Energy Critical Infrastructure sector)27 under DHS’s National
Infrastructure Protection Plan (NIPP).28 The ESCC draws its membership from all segments of the electric
utility industry, and is led by three chief executive officers – one each from the American Public Power
Association, the Edison Electric Institute, and the National Rural Electric Cooperative Association.29
Among its activities, the ESCC coordinates industry and government efforts on grid security, guides
infrastructure investments and R&D for critical infrastructure protection, seeks to improve threat
information sharing and processes with public- and private-sector stakeholders, and coordinates cross
sector activities with other critical infrastructure sectors.
The bulk electric power system has mandatory and enforceable standards for cybersecurity. The Energy
Policy Act of 2005 (EPACT) (P.L. 109-58) gave the Federal Energy Regulatory Commission authority
over the reliability of the grid, with the power to approve mandatory cybersecurity standards proposed by
the Electric Reliability Organization (ERO). Currently, the North American Electric Reliability
Corporation (NERC) serves as the ERO. NERC therefore proposes reliability standards for critical
infrastructure protection (CIP) which are updated considering the status of reliability and cybersecurity
concerns for the grid. FERC recently added mandatory and enforceable physical security requirements to
its critical infrastructure protection standards.30
The electric utility industry also conducts a biennial grid security and emergency response exercise
(GridEx) in which electric power and other stakeholders respond to simulated cyber and physical attacks.
The most recent exercise, GridEx III took place on November 18-19, 2015, and involved 364
organizations from across North America.31
In the event of a wide-scale power outage caused by a major attack or a disaster, electric utility efforts to
restore power would likely have to be augmented by state and federal resources. Given the potential for
damage to the nation’s economy from a major attack on the grid, some might suggest a greater focus on
recovery is needed and should become as much a part of a grid security strategy as the efforts to secure
the system. NERC has essentially agreed, saying in its GridEx III report that severe emergency situations
may require greater coordination with states and the federal government to identify physical risks to

27 The Energy Critical Infrastructure sector includes the electricity, petroleum, and natural gas subsectors. Department of
Homeland Security, Critical Infrastructure Sectors, 2015, https://www.dhs.gov/critical-infrastructure-sectors.
28 Department of Homeland Security, National Infrastructure Protection Plan, October 27, 2015, https://www.dhs.gov/national-
infrastructure-protection-plan.
29 Edison Electric Institute, Electric Subsector Coordinating Council, March 2015,
http://www.eei.org/issuesandpolicy/cybersecurity/Documents/ESCC%20Brochure.pdf.
30 However, these rules largely do not apply to distribution system utilities which are subject to mostly state regulation. FERC
Order No. 773 establishes a “bright-line” threshold essentially considering all transmission facilities and related facilities
operating at 100 kilovolts or above to be part of the bulk electric power system. As such, these facilities are subject to the
applicable NERC reliability standards.
31 “The electricity industry participants included chief executives from investor and publicly owned utilities, cooperatives, and
independent system operators from the U.S. and Canada. The U.S. federal and state governments were represented by senior
officials from various departments and agencies. In addition, approximately 70 individuals associated with the participants
attended the tabletop as observers to provide feedback.” Observers included the White House; National Security Council;
Department of Energy; Department of Homeland Security, including Federal Emergency Management Agency; Department of
Defense, including U.S. Cyber Command, U.S. Northern Command, North American Aerospace Defense Command; National
Security Agency; Federal Bureau of Investigation; and the National Guard. North American Electric Reliability Corporation,
Grid Security Exercise - GridEx III, March 2016,
http://www.nerc.com/pa/CI/CIPOutreach/GridEX/NERC%20GridEx%20III%20Report.pdf. (Hereinafter, GridExIII).
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electricity facilities, and to identify cyber risks in addressing malware on control systems before recovery
efforts could begin.32
Congress included provisions to give the U.S. Department of Energy (DOE) new authority to order
electric utilities and NERC to implement emergency security actions in the “Fixing America’s Surface
Transportation Act” (FAST; P.L. 114-94).33 DOE is designated as the lead sector specific agency for
cybersecurity for the Energy sector.34 Section 61004 of FAST also requires DOE (in consultation with
FERC, NERC, and electrical infrastructure operators) to develop a plan for storing spare large power
transformers and emergency mobile substations which can be quickly deployed to replace damaged large
power transformers and substations which serve grid-critical functions.35
Areas for Further Congressional Consideration
In any discussion of extended power outages, two prominent themes emerge—preparation and recovery.
If utilities are aware of an impending storm or weather-related event which may cause outages, they are
expected to make preparations for restoration of services in as timely a manner as possible. Recovery
from any such event will depend on the severity of the storm and the resulting damage. Recovery can be
hastened, and the amount of damage to electric power infrastructure can be minimized, if good
maintenance, restoration, organization, and communications strategies are followed on an ongoing basis.
However, a coordinated, major cyber and physical attack on the electric grid would severely test the
ability of the nation to recover, especially as plans for such a recovery are currently in progress. The
electric utility industry generally bases its response to the potential for such events based on the perceived
risks. The industry relies on the federal government to share relevant, real-time intelligence on risks from
terrorism or cybersecurity threats, communicating the quality of threat information in a timely manner so
it can respond appropriately. Improvements in threat/risk assessment would aid this process.
A focus on recovery would have to consider the mutual dependence and implications to other critical
infrastructure (especially communications systems)36 of an electric grid failure, and how quickly such
impacts could proliferate if not planned for in advance. Congress may consider how the grid of the future
will address cyber and physical security concerns, as more distributed generation is incorporated. The
U.S. electric grid is evolving. Incorporating elements to increase system resiliency as it develops will aid
in reducing the vulnerability of the system.
NERC itself concluded in its report on GridEx III that, after a major grid disruption, restarting generation
and energizing transmission and distribution systems would be a first priority. Restoring service to
communications systems, oil and gas, water supply/treatment and hospital customers would be a
secondary priority. Electric power systems may be operating at reduced levels of service and reliability

32 Ibid. Page 15.
33 Section 61003 of FAST creates a new section 215A of the Federal Power Act, that following a written determination by the
President, authorizes DOE to order utilities, the North American Electric Reliability Corporation (NERC), and Regional Entities
to implement emergency security measures for up to 15 days at a time.
34 The energy sector is one of 16 critical infrastructure sectors identified in Presidential Policy Directive-21 (PPD-21), Critical
Infrastructure Security and Resilience. Sector specific agencies are designated with specialized expertise in those critical
infrastructure sectors that are tasked with various roles and responsibilities for their respective sectors, as specified in PPD-21
(i.e., development of sector-specific plans, coordination with the Department of Homeland Security, and incident management
responsibilities).
35 Paul Parfomak, Electric Grid Physical Security: Recent Legislation, CRS Insight IN10425, 2016.
36 “[PPD-21] identifies energy and communications systems as uniquely critical due to the enabling functions they provide across
all critical infrastructure sectors.” The White House, Presidential Policy Directive—Critical Infrastructure Security and
Resilience, Presidential Policy Directive / PPD-21, February 12, 2013, https://www.whitehouse.gov/the-press-
office/2013/02/12/presidential-policy-directive-critical-infrastructure-security-and-resil.
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for an extended period at such a time. Congress may consider how planning for subsequent restoration of
services would proceed to ensure that all civilian communities are kept informed, and treated as equitably
as possible in disaster recovery efforts.



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