Ensuring Electricity Infrastructure Resilience 
December 14, 2022 
Against Deliberate Electromagnetic Threats  
Brian E. Humphreys 
Detonation of a nuclear weapon in the Earth’s upper atmosphere or near-Earth space may 
Analyst in Science and 
generate a series of electromagnetic pulses—known as high-altitude electromagnetic pulse 
Technology Policy 
(HEMP)—that damage critical infrastructure on the Earth’s surface. Observers are most 
  
concerned about potential HEMP effects on the electricity sector, given its specific vulnerabilities 
to electromagnetic threats and its role in maintaining the full range of essential infrastructure 
 
functions nationwide.  
Scientists believe HEMP is generated by the interaction of the radiation and blast effects of an exploding nuclear device with 
the earth’s upper atmosphere, magnetic field, and conductive geologic formations. HEMP has three main time components, 
usually labeled E1, E2, and E3, which occur in rapid sequence and create distinct and potentially hazardous effects over a 
broad geographic area. The E1 pulse may directly radiate sensitive electronics or couple with electrical equipment via control 
cables or other conductors. The E2 pulse has effects similar to lightning. The E3 pulse may induce currents in long-distance 
transmission lines that damage or disrupt large power transformers (LPTs) and other essential equipment. 
While there is broad consensus in the electricity industry, the research community, and among policymakers that HEMP 
attacks may pose risk to electricity infrastructure, there is disagreement regarding specific HEMP hazard characteristics, the 
level of risk, and the need for—or feasibility of—expansive hardening initiatives. Although the basic theories underlying 
HEMP research are well-established, HEMP involves a range of complex physical phenomena—from sub-atomic processes 
to complex interactions of networked infrastructure systems under stress—which are not fully understood. The degree (and 
policy relevance) of scientific uncertainty is itself a significant source of disagreement among stakeholders.  
In recent decades, Congress has pressed the research community and relevant federal agencies to advance scientific 
understanding of HEMP-related hazards to infrastructure, and to produce more authoritative risk assessments to inform both 
policy development and industry action. Congress has enacted a variety of mandates—primarily via national defense 
authorization acts—to spur basic research, applied research, and technology development, as well as risk management 
activities such as risk assessments, adoption of voluntary standards and best practices, and the expansion of public-private 
partnerships for coordination and information sharing with industry. A congressionally-chartered expert commission 
provided congressional testimony, reports, and recommendations between 2004 and 2017.  
The 117th Congress has appropriated funds for new infrastructure investments through the Infrastructure Investment and Jobs 
Act (IIJA; P.L. 117-58) and the Inflation Reduction Act (IRA; P.L. 117-169), even as implementation of previous mandates 
continued. Rapid introduction of solar and wind generation of electricity, microgrids, and utility-scale energy storage may 
offer potential resilience benefits, but could also introduce new vulnerabilities. Likewise, new operational control 
technologies to support integration of distributed energy resources with existing distribution networks may offer additional 
flexibility and resilience to the grid—assuming potentially sensitive electronic components are not damaged by HEMP. 
Research into the resilience of these technologies against HEMP is in its early stages. Research gaps complicate guidance to 
policymakers or industry stakeholders on near-term prioritization of critical systems and assets for hardening or other 
countermeasures. As a remedy, some IIJA provisions include HEMP research as an authorized activity. Other provisions may 
support HEMP research, but do not specifically authorize it. Actual support for HEMP resilience will largely depend upon 
how funds are apportioned to specific programs by implementing agencies.  
Several other issues for Congress may also warrant attention. Gaps in data used to model HEMP hazards and their effects on 
infrastructure have long been identified as an obstacle to providing more authoritative risk assessments to key stakeholders. 
Improved coordination and information sharing between defense and civilian researchers may address some gaps. 
Additionally, resilience of new technologies to HEMP is an emerging concern. Congress may support additional research and 
development of resilience standards through its oversight and legislative authorities, while considering potential future 
technological advancements as appropriate. Emerging solid state technologies may enable introduction of standardized 
systems to replace older technologies, such as LPTs that require long lead times for manufacture, customization, and 
transport. Given the long service life of most electricity infrastructure assets, it may be appropriate to encourage investment 
in next-generation technologies, where possible, to avoid inefficient use of limited resources to harden obsolescent 
technologies against HEMP. 
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Ensuring Electricity Infrastructure Resilience Against Electromagnetic Pulse Threats  
 
Contents 
Introduction ..................................................................................................................................... 1 
High-Altitude Electromagnetic Pulse (HEMP) and Hazards to Electricity Infrastructure .............. 2 
The HEMP Waveform ............................................................................................................... 2 
E1: Early Time Pulse ................................................................................................................. 3 
E2: Intermediate Time Pulse ..................................................................................................... 5 
E3: Late Time Pulse .................................................................................................................. 5 
The CISR Framework and HEMP ................................................................................................... 7 
Strategies, Plans, Policies, and Legislation ..................................................................................... 9 
Agency Strategies and Action Plans .......................................................................................... 9 
The EMP Commission ............................................................................................................ 10 
Executive Order (E.O.) 13865 and the FY2020 NDAA ......................................................... 10 
HEMP and Infrastructure Legislation in the 117th Congress ................................................... 13 
HEMP-Specific Provisions in the IIJA ............................................................................. 13 
Other Potentially Relevant IIJA Grid Resilience Provisions ............................................ 14 
Research Issues .............................................................................................................................. 15 
HEMP Environments and Benchmarks ................................................................................... 15 
Modeling and Simulation of Infrastructure Resilience ........................................................... 16 
Summary of HEMP Research Results ..................................................................................... 17 
Emerging Science and Technology Policy Issues.......................................................................... 18 
Inverter-Based Resources ........................................................................................................ 19 
Microgrids ............................................................................................................................... 20 
Transmission Facilitation and Grid Flexibility ....................................................................... 20 
Undergrounding Electrical Equipment and Power Lines ........................................................ 21 
Issues for Congress ........................................................................................................................ 22 
Obstacles to Improved Risk Management .............................................................................. 22 
Incentivizing and Facilitating Investment in HEMP Resilience ............................................. 23 
Future Technological Advancements ...................................................................................... 24 
 
Figures 
Figure 1. Representation of HEMP Electric Field ........................................................................... 3 
Figure 2. Potential HEMP E1 Effects of 1,000 Kiloton Weapon at 200 km Altitude over 
Central United States .................................................................................................................... 4 
Figure 3. Notional Geoelectric Field of “Heave” E3B Pulse at 40 Seconds ................................... 6 
  
Tables 
Table 1. HEMP E1 Maximum Waveforms as a Function of Weapon Yield and Altitude ............... 4 
Table 2. EMP/GMD-Related Requirements in FY2020 NDAA .................................................... 11 
  
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Appendixes 
Appendix A. Selected Studies by Year .......................................................................................... 25 
 
Contacts 
Author Information ........................................................................................................................ 27 
 
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Ensuring Electricity Infrastructure Resilience Against Electromagnetic Pulse Threats  
 
Introduction 
Detonation of a nuclear weapon in the upper atmosphere or in near-Earth space may generate a 
series of electromagnetic pulses—known collectively as high-altitude electromagnetic pulse 
(HEMP)—that damage the electric grid and other critical infrastructure on the earth’s surface.1 
HEMP may directly radiate and damage sensitive electronics used to operate the grid, or couple 
with transmission lines and other conductors attached to essential equipment. This report focuses 
on HEMP-related risk to the electric grid, given its centrality to the operation of many other 
critical networked systems, such as water, transport, and communications. Other deliberate 
electromagnetic threats, such as battlefield electromagnetic pulse (EMP) weapons or improvised 
devices powered by conventional explosives, are outside the scope of this report. Likewise, this 
report does not provide an assessment of intent or capabilities of potential adversaries, or the 
likelihood of a HEMP attack.2  
While there is broad consensus in the electricity industry, the research community, and among 
policymakers that high-altitude electromagnetic pulse attacks may pose risk to electricity 
infrastructure, there is disagreement regarding specific HEMP hazard characteristics, the level of 
risk, and the need for—or feasibility of—expansive HEMP-hardening initiatives.3  
Congress has enacted a variety of mandates—primarily via national defense authorization acts—
to spur basic research, applied research, and technology development, as well as risk management 
activities, risk assessments, adoption of voluntary standards and best practices, and the expansion 
of public-private partnerships for coordination and information sharing with industry. A 
congressionally chartered expert commission provided congressional testimony, reports, and 
recommendations between 2004 and 2017.  
Most federal legislation has focused on the electricity sector, reflecting the broad consensus and 
priorities of government, industry, and the research community. Implementation of previous 
congressional mandates is ongoing, even as the 117th Congress has appropriated funds for new 
infrastructure investments through the Infrastructure Investment and Jobs Act (IIJA; P.L. 117-58), 
the Inflation Reduction Act (IRA; P.L. 117-169), and other legislation. Prospective upgrades and 
buildout of electricity infrastructure may affect the sector’s overall resilience to HEMP hazards, 
                                                 
1 The Cybersecurity and Infrastructure Security Agency (CISA), a Department of Homeland Security agency, 
designates electricity as a subsector of the Energy critical infrastructure sector, which includes generation, 
transmission, and distribution except for hydroelectric and commercial nuclear power facilities. See Department of 
Homeland Security and Department of Energy, 
Energy Sector Specific Plan, Washington, DC, 2015, p. 3, 
https://www.cisa.gov/sites/default/files/publications/nipp-ssp-energy-2015-508.pdf. As used in this report, “electricity 
sector” encompasses the entirety of the national generation, long distance transmission, and local distribution 
infrastructure. 
2 The congressionally-chartered Commission to Assess the Threat to the United States from Electromagnetic Pulse 
Attack (the EMP Commission) released several papers assessing foreign adversaries’ intent and capabilities prior to its 
dissolution. See Peter Vincent Pry, 
Foreign Views of Electromagnetic Pulse Attack, the EMP Commission, 
Washington, DC, July 2017; ibid., 
Political Military Motives for Electromagnetic Pulse Attack, the EMP Commission, 
Washington, DC, July 2017; and ibid., 
Nuclear EMP Attack Scenarios and Combined-Arms Cyber Warfare, 
Washington, DC, July 2017. Available online at http://www.firstempcommission.org/.
 
3 Some experts believe that certain of these hardening measures to protect essential grid equipment or maintain 
stockpiles of spare equipment may make the grid more resilient against more-frequently occurring electromagnetic 
threats from space weather, cyber, or physical attacks, providing additional potential benefits. See The Commission to 
Assess the Threat to the United States from Electromagnetic Pulse (EMP) Attack, Report of the Commission to Assess 
the Threat to the United States from Electromagnetic Pulse (EMP) Attack, Critical National Infrastructures (the EMP 
Commission critical infrastructure report),Washington, DC, April 2008, p. 53, http://www.firstempcommission.org/
uploads/1/1/9/5/119571849/emp_comm._rpt._crit._nat._infrastructures.pdf. 
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either by design or by chance. Congress may exercise oversight of related programs and activities 
to ensure that HEMP resilience is incorporated into electricity infrastructure at desired levels.  
This report provides information on (1) the basic physics of HEMP; (2) existing risk management 
approaches and related legislation, policies, and directives; (3) the current state of scientific 
knowledge and related research programs; and (4) emerging science and technology policy 
issues. A concluding section summarizes potential issues for Congress.  
High-Altitude Electromagnetic Pulse (HEMP) and 
Hazards to Electricity Infrastructure 
U.S. and Soviet high-altitude weapons tests in the upper atmosphere in the late 1950s and early 
1960s suggested that the electromagnetic effects of nuclear bombs detonated at high altitude 
(above 30 km) were potentially damaging to electrical grids, communications infrastructure, and 
other vital electronics-based systems many hundreds of miles away from the blast epicenter. 
Therefore, HEMP became a phenomenon of concern to military and civil defense planners. 
The Partial Test Ban Treaty of 1963, signed by the United States, the United Kingdom, and the 
Soviet Union, precluded further scientific observations of HEMP effects on infrastructure in situ.4 
However, military and civilian scientists have continued theoretical work and laboratory testing 
on grid components and other electronics. In addition, naturally occurring space weather produces 
geomagnetic disturbances (GMD)—comparable in some aspects to the late-time (E3) 
magnetohydrodynamic pulse produced during HEMP events—that inform empirical research on 
large-scale electromagnetic hazards to infrastructure in natural settings.5  
The HEMP Waveform 
In general, scientists believe HEMP is generated by the interaction of the radiation and blast 
effects of an exploding nuclear device with the earth’s upper atmosphere, magnetic field, and 
conductive geologic formations. HEMP has three main time components, usually labeled E1, E2, 
and E3, which occur in rapid sequence and create distinct and potentially hazardous effects over a 
broad geographic area. 
                                                 
4 See the National Archives, “Test Ban Treaty (1963),” https://www.archives.gov/milestone-documents/test-ban-treaty. 
5 Space weather refers to the dynamic conditions in Earth’s outer space environment. This includes conditions on the 
Sun, in the solar wind, and in Earth’s upper atmosphere. Both space weather-related geomagnetic disturbances and the 
late-time high-altitude magnetohydrodynamic pulse cause disturbances in the Earth’s ambient magnetic field that may 
cause geologically induced currents, although there are significant differences in rise time, duration, geographic 
distribution, and amplitude. See Ross Guttromson, Craig Lawton, and Matthew Halligan, et al., 
Electromagnetic 
Pulse—Resilient Electric Grid for National Security: Research Program Executive Summary, Sandia National 
Laboratories, SAND2020-11227, Albuquerque, NM, October 2020, p. 15; and Maj. David Stuckenberg, 
“Electromagnetic Pulse Threats to America’s Electric Grid: Counterpoints to Electric Power Research Institute 
Positions,” 
Over the Horizon: Multi-Domain Operations and Strategy, pp. 17-18, August 27, 2019. For more 
information on space weather threats to infrastructure and federal risk management programs and activities, see CRS 
Report R46049, 
Space Weather: An Overview of Policy and Select U.S. Government Roles and Responsibilities, by Eva 
Lipiec and Brian E. Humphreys.  
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Figure 1. 
Representation of HEMP Electric Field 
 
Source: Edward Savage, James Gilbert, and Wil iam Radasky, 
The Early-Time (E1) High-Altitude Electromagnetic 
Pulse (HEMP) and Its Impact on the U.S. Power Grid, Metatech, Meta-R-320, Goleta, CA, January 2010, p. 2-2.  
Notes: E(t) (V/m) = electric field in Volts per meter. s = seconds. E1 is seen in the upper left quadrant of the 
graph as a rapid rise in electromagnetic energy. E2 is seen in a less pronounced peak in the middle of the graph. 
E3 is seen at the far right as two lower amplitude pulses. The graph is il ustrative and provides only a generic 
representation of HEMP electric fields and timescales. 
E1: Early Time Pulse 
The fission component of a modern nuclear weapon (typically used to trigger a more powerful 
fusion reaction) releases an intense burst of gamma radiation within the first microsecond of 
detonation. When detonations occur at high altitude, the radiation ionizes air molecules in the 
gamma absorption layer roughly 30 kilometers (km) above the earth’s surface. Electrons freed by 
this process scatter and interact with the earth’s upper atmosphere and magnetic field before 
losing their energy and being reabsorbed a short time later. The brief, but high energy, movement 
of free electrons along the lines of the earth’s ambient magnetic field generates a secondary 
electromagnetic pulse. Dependent on a number of conditions, part of this pulse may radiate 
downward towards Earth’s surface as a high-amplitude radio signal.6  
Although this E1 pulse may reach continental scale, the maximum strength of the electric field it 
generates—measured in kilovolts per meter (kV/m)—is concentrated within a smaller crescent-
shaped area equatorward (i.e., southward in the Northern hemisphere) of the blast epicenter (see 
Figure 2) due to the influence of the Earth’s magnetic field. The E1 pulse may damage electrical 
systems and electronic devices in two ways: (1) direct radiation of internal components, or (2) 
coupling with conductors, such as power transmission lines, power control lines, and certain 
                                                 
6 For detailed description of HEMP physics, see Michael Kelly Rivera, Scott N. Backhaus, and Jesse Richard 
Woodroffe, et al., 
EMP/GMD Phase 0 Report, A Review of EMP Hazard Environments and Impacts (the LANL study), 
Los Alamos National Laboratory, LA-UR-16-28380, Los Alamos, NM, November 7, 2016, pp. 13-34, 
https://www.osti.gov/biblio/1330652. This section synthesizes descriptions of HEMP physics found in the LANL study 
and other studies cited in this report. According to the LANL study, most contemporary HEMP research is based on 
theories and insights from a series of research papers published between 1962 and 1986 by W.J. Karzas and Richard 
Latter, and Conrad Longmire et al. The authors provide the following disclaimer about their description of E1 physics: 
“To aid in the understanding of the phenomena, a number of [technically inaccurate] simplifications have been made. ... 
Although we have presented the above as if it was ‘settled’ science, by no means is this the case. Models of the E1 
pulse incorporating more physical effects and more detail on the effects we described above are still being developed to 
this day” (p. 27). 
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communications lines, which act as antennae and may conduct damaging voltage surges into 
connected devices.  
Figure 2. Potential HEMP E1 Effects of 1,000 Kiloton Weapon at 200 km Altitude 
over Central United States 
 
Source: Los Alamos National Laboratory, in Electric Power Research Institute (EPRI), 
High-Altitude 
Electromagnetic Pulse and the Bulk Power System: Potential Impacts and Mitigation Strategies (the EPRI study), Palo 
Alto, CA, April 2019, p. 2-3, https://www.roxtec.com/globalassets/03.-files/campaign-pages/emc/2019-epri-
report.pdf. 
The strength of the E1 pulse is only weakly correlated with increased weapon yield, because the 
same process that generates the radio signal described above also creates a powerful return 
current that builds throughout the E1 phase of the HEMP event. The return current partially 
attenuates the primary signal.7 Height of burst also affects the strength of HEMP E1 hazard fields 
measured on the earth’s surface. E1 effects are limited to line of sight from the epicenter to the 
earth’s surface, so that detonations at higher altitudes affect a wider geographic area. As with any 
source of radiation, the intensity of illumination decreases with distance from the source. Any 
given weapon yield has an “optimal” height of burst wherein the strength of the hazard field 
created by the E1 pulse is maximized as shown i
n Table 1. 
Table 1. HEMP E1 Maximum Waveforms as a Function of Weapon Yield and Altitude 
Yield (kilotons) 
Altitude (km) 
Epeak (kV/m) 
10 
50 
18 
30 
58 
26 
100 
67 
36 
300 
77 
46 
1,000 
88 
57 
Source: Defense Threat Reduction Agency (DTRA), Department of Defense (DOD). 
Notes: Adapted by CRS. For comparison, yield of the bombs used to destroy Hiroshima and Nagasaki were 
estimated by LANL in 1985 to be 15 kilotons and 21 kilotons respectively. Yield of modern Russian strategic 
weapons deployed on intercontinental ballistic missiles range between 100 and 800 kilotons, according to a 2022 
Bul etin of the Atomic Scientists report.  
                                                 
7 LANL study, pp. 26-27. 
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The geographic area of maximum E1 electric field strength does not necessarily overlap with the 
geographic areas where infrastructure assets are most vulnerable to E1 hazards, according to a 
2019 study by the Electric Power Research Institute (EPRI), an industry group. The report states 
that “maximum coupling generally occurs in areas to the east and west of ground zero and not 
south of ground zero where the area of maximum electric field amplitude is located.”8  
Peak field strength is therefore only one of several factors affecting overall risk to exposed 
electricity infrastructure. Other factors listed in the EPRI study include polarization of the E1 
field, incidence angle between burst location and location of the asset on the ground, and 
azimuthal angle—the angle between the wave of electromagnetic energy and a wire or other 
conductor on or near the Earth’s surface.9  
E2: Intermediate Time Pulse 
The E2 pulse (between 1 microsecond and 1 tenth of a second after detonation) is also generated 
by the fission component of a nuclear weapon.10 The E2 pulse creates an electric discharge 
similar to lightning in its basic physics, but occurring over a much wider geographic area. Many 
scientists believe protective equipment that is already installed to prevent damage to the electric 
grid from lighting strikes is sufficient to mitigate E2 effects. However, some have cautioned that 
the earlier E1 pulse may damage this protective equipment, leaving grid infrastructure exposed to 
hazardous effects of the E2 pulse.11 Despite this uncertainty, most EMP research focuses on the 
E1 and E3 pulses and their effects.  
E3: Late Time Pulse 
E3 is generated by the fusion component of a nuclear device. The physics and time scale of the 
E3 pulse differ from those of E1 and E2, because E3 is produced by the explosive effects of the 
device, not the initial release of gamma radiation from the fission reaction described above (see 
the 
“E1: Early Time Pulse” section). According to the LANL study, “The primary physical effect 
at work in the E3 phase involves the motion of plasma, ionized weapon debris, and ionized 
atmosphere within the Earth’s magnetic field.”12 In general, E1 and E3 effects cannot be 
maximized simultaneously with a single weapon, because parameters such as optimal weapon 
yield and optimal detonation altitude are different for E1 and E3. Even so, significant E1 and E3 
effects on the earth’s surface may overlap in some cases.13 
                                                 
8 Electric Power Research Institute (EPRI), 
High-Altitude Electromagnetic Pulse and the Bulk Power System: Potential 
Impacts and Mitigation Strategies (the EPRI study), Palo Alto, CA, April 2019, p. 2-9, https://www.roxtec.com/
globalassets/03.-files/campaign-pages/emc/2019-epri-report.pdf. 
9 The EPRI study, pp. 2-7–2-8. 
10 The LANL study, p. 18. 
11 A.G. Tarditi, J.S. Besnoff, and R.C. Duckworth, et al., 
High-Voltage Modeling and Testing of Transformer, Line 
Interface Devices, and Bulk System Components Under Electromagnetic Pulse, Geomagnetic Disturbance, and Other 
Abnormal Transients, Oak Ridge National Laboratory (ORNL), ORNL/TM-2019/1143, Oak Ridge, TN, March 18, 
2019, p. 4 and 8; and the EMP Commission critical infrastructure report, p. 33, http://www.firstempcommission.org/
uploads/1/1/9/5/119571849/emp_comm._rpt._crit._nat._infrastructures.pdf. 
12 The LANL study, p. 27. 
13 Brian Pierre, Daniel Krofcheck, and Matthew Hoffman, et al., 
EMP-Resilient Grid Grand Challenge: Task 3.1 Final 
Report, Modeling Framework for Bulk Electric Grid Impacts from HEMP E1 and E3 Effects, SAND2021-0865, 
Albuquerque, NM, January 2021, p. 20, https://www.osti.gov/biblio/1764794. 
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The two primary components of the E3 pulse are the “blast” component (E3A) and the “heave” 
component (E3B). The E3A component is caused by the expansion of a large superheated 
conductive plasma ball produced by the detonation. The plasma ball pushes the earth’s ambient 
geomagnetic field lines 
outwards as it expands and rises through the upper atmosphere. Much of 
the E3A component is attenuated by the effects of atmospheric absorption of the weapon’s x-ray 
emissions below the blast epicenter, and so presents a lesser risk to infrastructure. 
The E3B pulse is produced later as the plasma ball and associated effects dissipate, and the 
“ionized remnants of bomb debris and shock-heated atmospheric ions” settle in the upper 
atmosphere below the blast epicenter. This creates a conductive “hot ion patch,” which heats and 
expands. This heated conductive patch becomes buoyant and rises through the upper atmosphere, 
producing an artificial geomagnetic disturbance as it pulls the geomagnetic field lines 
inwards.14 
According to a LANL model of an E3B environment, location of peak voltages changes over the 
course of the event.15
 Figure 3 depicts the geoelectric hazard field 40 seconds after the blast. 
Figure 3. Notional Geoelectric Field of “Heave” E3B Pulse at 40 Seconds 
10,000 Kiloton Yield at 200 km (Magnitude in V/km) 
 
Source: LANL diagram in EPRI Study. 
Notes: The graphic does not depict predicted effects of a specific weapon.  
As with E1, weapon yield and height of burst affect the strength of the resulting E3B hazard field. 
However, the magnitude of the E3B pulse does not increase much after weapon yield exceeds 10 
kilotons—a yield typical of a small tactical warhead. However, the surface area of the hot ion 
patch increases with weapon yield and may disrupt Earth’s magnetic field over a larger area.16 A 
larger patch presents greater risk to electricity infrastructure, because the resulting E3B pulse 
causes geomagnetic induced currents (GIC) that build cumulatively as they flow through long 
conductors, such as long-distance transmission lines.17  
                                                 
14 See the LANL study, p. 35.  
15 See the EPRI study, p. 2-11. 
16 See the LANL study, pp. 38-39; and James Gilbert, John Kappenman, and William Radasky, et al., 
The Late Time 
(E3) High-Altitude Electromagnetic Pulse (HEMP) and Its Impact on the U.S. Power Grid, Metatech, Meta-R-321, 
Goleta, CA, January 2010, p. 2-15, http://www.futurescience.com/emp/ferc_Meta-R-321.pdf.  
17 For detailed description of E3 physics, see Jeffrey J. Love, Greg M. Lucas, and Benjamin S. Murphy, et al., “Down 
to Earth with Nuclear Electromagnetic Pulse: Realistic Surface Impedance Affects Mapping of the E3 Geoelectric 
Hazard,” 
Earth and Space Science, vol. 8 (2021).  
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GIC may saturate the magnetic cores of large power transformers (LPTs) that enable transmission 
and local distribution of alternating current at useable voltages. According to a Department of 
Energy (DOE) study on naturally-occurring geomagnetic disturbances, saturation of the magnetic 
cores of LPTs by GIC can cause several damaging effects:18  
  harmonic currents that can cause relays to trip equipment; 
  fringing magnetic fields (i.e., flux outside the core) that can create heating in the 
transformer, which, if sufficiently high and of long duration, can lead to 
overheating and reduction of a transformer’s life; 
  increased reactive power consumption that can cause the system to collapse due 
to voltage instability;19 and 
  damage and upset of customer equipment due to power quality disturbances. 
In addition, GIC may cause harmonic damage to generator rotors and thermal damage to static 
VAR compensators that provide reactive power to the grid, according to industry sources.20 
The CISR Framework and HEMP 
The technical summary presented above is a simplification of complex phenomena that are the 
subjects of continuing scientific research programs across numerous disciplines and sub-
disciplines. The degree (and policy relevance) of scientific uncertainty is itself a significant 
source of disagreement among stakeholders in the national critical infrastructure security and 
resilience (CISR) enterprise. Industry stakeholders generally wish to avoid what some see as 
costly mandates to invest in unproven technologies based on limited scientific research, while 
some policymakers and advocacy groups believe the existing knowledge and technological bases 
are sufficient to justify an expansive hardening program across vulnerable critical infrastructure 
sectors.21  
Industry adoption of EMP-hardened equipment in the electricity sector is market-driven in the 
United States. Equipment manufacturers may choose from among available hardening standards 
or specify their own proprietary testing criteria if they wish to make EMP resilience part of their 
                                                 
18 For example, see DOE, Division of Infrastructure Security and Energy Restoration, 
Geomagnetic Disturbance 
Monitoring Approach and Implementation Strategies, Washington, DC, January 2019, p. 3.  
19 Apparent power of a given AC system is a function of reactive power measured in Volts-Amps Reactive (VAR) used 
for voltage support, and active power used for lighting, heating, operation of machinery, and other useful work. 
Consumers are typically billed for active power. For a summary description, see Federal Energy Regulatory 
Commission, 
Reliability Primer, Washington, DC, p. 18, https://www.ferc.gov/sites/default/files/2020-04/reliability-
primer_1.pdf. 
20 See ABB Inc., 
SolidGround Grid Stability and Harmonics Mitigation System, Mount Pleasant, PA, 2015, p. 3, 
https://search.abb.com/library/Download.aspx?DocumentID=2GNM110098. 
21 For discussion of industry perspectives on costs, see Government Accountability Office (GAO), 
Critical 
Infrastructure Protection: Electricity Suppliers Have Taken Actions to Address Electromagnetic Risks, and Additional 
Research Is Ongoing, GAO-18-67, Washington, DC, February 7, 2018, pp. 47-50; and Maj. David Stuckenberg, op cit., 
p. 7. Stuckenberg suggests that EPRI focused its EMP research on areas of grid operations (transmission and sub-
station components) with strongest chances for early cost recovery of any mitigation investments. The North American 
Electric Reliability Corporation (NERC), the industry-led electric reliability organization for the bulk power system, 
stated in testimony to Congress in 2012 that HEMP events were acts of war and therefore defense against them was a 
federal responsibility. See U.S. Congress, House Committee on Homeland Security, Subcommittee on Cybersecurity, 
Infrastructure Protection, and Security Technologies, 
The EMP Threat: Examining the Consequences, Statement of the 
North American Reliability Corporation, 112th Cong., 2nd sess., September 12, 2012.  
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product marketing.22 In some cases, manufacturers have also advertised the successful use of their 
equipment in testing by federal agencies or federally-sanctioned industry reliability 
organizations.23 Companies may self-certify or seek third-party certification from an accredited 
body to indicate compliance with specific standards. Electricity producers may then decide 
whether the cost premium for hardened equipment is justified, given their specific risk profiles 
and tolerances.  
Because much of the nation’s critical infrastructure is owned and operated by the private sector 
on a for-profit basis, implementation of federal initiatives to counter known threats to 
infrastructure, including HEMP, often depends on industry engagement in public-private 
partnerships for resilience. Such engagement may involve sharing potentially sensitive 
information with government and non-government stakeholders, investing in research, and 
making relevant resilience investments based on available risk assessments and protection 
standards. These investments may involve significant up-front business costs that must be 
absorbed or passed to customers.  
Federal initiatives to increase infrastructure resilience to HEMP hazards—often in response to 
congressional mandates or executive branch directives—have generally assumed the voluntary 
public-private partnership model as the basis for programs and activities. There is no federal 
regulatory requirement for hardening of critical infrastructure against HEMP.24 Likewise, there is 
no relevant reporting requirement or centralized database containing information about industry 
adoption of hardening measures. However, the Department of Homeland Security (DHS) 
administers voluntary protected disclosure programs.25 According to some observers, private-
sector investment in HEMP resilience has generally been uneven and limited.26 
Under the current regulatory framework, the federal government oversees reliability for the 
generation and transmission systems of the electric power sector. These components comprise the 
                                                 
22 For an overview of standards and their application to EMP protection, see William A. Radasky, “Protecting Industry 
from HEMP and IEMI,” 
In Compliance: Electronic Design, Testing & Standards, October 31, 2018, 
https://incompliancemag.com/article/protecting-industry-from-hemp-and-iemi/.  
23 ABB Inc., ibid., p. 6, https://search.abb.com/library/Download.aspx?DocumentID=2GNM110098. 
24 NERC has issued standards for transmission operators to have GMD operating plans in place, to counter effects of 
space weather events. Such plans rely upon space weather forecasting and advance warning of major GMD events. 
These standards do not apply to manmade events that may occur with little or no notice, such as HEMP E3, and do not 
mandate specific equipment hardening measures. See DOE, Division of Infrastructure Security and Energy Restoration, 
Geomagnetic Disturbance Monitoring Approach and Implementation Strategies, Washington, DC, January 2019, pp. 6-
7. 
25 DHS administers the Protected Critical Infrastructure Information (PCII) program under authorities of the Critical 
Infrastructure Information Act of 2002 (Title II, Subtitle B, of P.L. 107-296) to encourage industry sharing of sensitive 
critical infrastructure information in exchange for confidentiality and limited immunities against regulatory action, 
involuntary disclosure to third parties, and litigation.  
26 For example Chris Beck, Eric Easton, and Carl Eng, et al., 
Electric Infrastructure Protection Handbook IV: 
Electromagnetic Pulse Protection Best Practices (the EIS study), the Electric Infrastructure Security (EIS) Council, 
Washington, DC, January 1, 2021, p. 18; also DOE, Division of Infrastructure Security and Energy Restoration, 
Geomagnetic Disturbance Monitoring Approach and Implementation Strategies, Washington, DC, January 2019, p. 12; 
and Government Accountability Office (GAO), 
Critical Infrastructure Protection: Electricity Suppliers Have Taken 
Actions to Address Electromagnetic Risks, and Additional Research Is Ongoing, GAO-18-67, Washington, DC: 
February 7, 2018. According to the GAO report, only 3 of 11 electricity suppliers who responded to GAO enquires 
about HEMP resilience activities reported having studied possible network impacts of HEMP events. See also the 
Commission to Assess the Threat to the United States From Electromagnetic (EMP) Pulse Attack, 
Assessing the Threat 
From Electromagnetic Pulse, Executive Report (EMP Commission Executive Report), Washington, DC, July 2017, pp. 
6-8, http://www.firstempcommission.org/uploads/1/1/9/5/119571849/
executive_report_on_assessing_the_threat_from_emp_-_final_april2018.pdf. 
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bulk power system. The Energy Policy Act of 2005 (EPACT05; P.L. 109-58) authorized the 
Federal Energy Regulatory Commission (FERC) and its certified electric reliability organization, 
the North American Electric Reliability Corporation (NERC), to develop and enforce mandatory 
reliability standards for the bulk power system.27  
In most cases, state and local authorities regulate local distribution systems and retail sales to 
customers, and may also mandate relevant reliability standards or specific risk mitigation 
activities. Federal or state regulatory authorities may allow for cost-recovery—i.e., passing costs 
of regulatory compliance on to customers. Alternatively, Congress or state legislatures may 
provide grants or otherwise direct relevant regulatory agencies to force utilities to absorb these 
costs.  
Strategies, Plans, Policies, and Legislation 
A variety of strategies, plans, policies, and legislation have guided federal efforts to understand 
and manage HEMP-related risks in recent decades. 
Agency Strategies and Action Plans 
In 2015, the Secretary of Energy directed DOE to develop an EMP resilience strategy (the DOE 
Joint Strategy) in coordination with the electric power industry through EPRI. DOE described the 
Joint Strategy, released in 2016, as “a public-private collaborative effort, designed to establish a 
common framework with consistent goals and objectives that will guide both government and 
industry efforts to increase grid resilience to EMP threats.”28 
The DOE Joint Strategy identified five goals:  
1.  improve and share understanding of EMP threat, effects, and impacts;  
2.  identify priority infrastructure;  
3.  test and promote mitigation and protection approaches;  
4.  enhance response and recovery capabilities to an EMP attack; and  
5.  share best practices across government and industry, nationally and 
internationally. An action plan based on the strategy was released in 2017.29 
 
In 2018, DHS released an EMP/GMD strategy (the DHS strategy) in fulfilment of a congressional 
mandate enacted by Section 1913 of the National Defense Authorization Act for 2017 (FY2017 
NDAA; P.L. 114-328).30 The strategy identified three main goals:  
                                                 
27 For an overview of federal reliability requirements and regulatory framework, see CRS Report R45764, 
Maintaining 
Electric Reliability with Wind and Solar Sources: Background and Issues for Congress, by Ashley J. Lawson, 
especially the section “Electric Reliability Regulatory Framework.” 
28 DOE and EPRI, 
Joint Electromagnetic Pulse Resilience Strategy: A Collaborative Effort of the U.S. Department of 
Energy and the Electric Power Research Institute, Washington, DC, July 2016, https://www.energy.gov/sites/prod/
files/2016/07/f33/DOE_EMPStrategy_July2016_0.pdf.  
29 DOE, 
U.S. Department of Energy Electromagnetic Pulse Resilience Action Plan, Washington, DC, January 2017, 
https://www.energy.gov/sites/prod/files/2017/01/f34/
DOE%20EMP%20Resilience%20Action%20Plan%20January%202017.pdf. 
30 Department of Homeland Security, 
Strategy for Protecting and Preparing the Homeland Against Threats of 
Electromagnetic Pulse and Geomagnetic Disturbances, Washington, DC, October 9, 2018, https://www.dhs.gov/sites/
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1.  improve risk awareness of electromagnetic threats and hazards;  
2.  enhance capabilities to protect critical infrastructure from the impact of an 
electromagnetic incident; and  
3.  promote effective electromagnetic-incident response and recovery efforts. DHS 
indicated that the strategy will remain in effect until 2026 and be updated every 
two years thereafter.31  
 
The EMP Commission  
Congress first established the Commission to Assess the Threat to the United States from 
Electromagnetic Pulse Attack (EMP Commission) under Title XIV of the Floyd D. Spence 
National Defense Authorization Act (NDAA) for Fiscal Year 2001 (P.L. 106-398). It was 
reestablished under Section 1052 of FY2006 NDAA (P.L. 109-163). Section 1075 of the FY2008 
NDAA (P.L. 110-181) modified the EMP Commission’s authorities, extending the deadline for 
previous reporting requirements among other provisions. The EMP Commission was 
reestablished for a second time under Section 1089 of the FY2016 NDAA (P.L. 114-92). Section 
1691 of the FY2018 NDAA (P.L. 115-91) established a new EMP Commission to complete 
another assessment and report due April 1, 2019, but the provision was subsequently repealed by 
Section 1695 of the FY2020 NDAA (P.L. 116-92).  
The EMP Commission released several reports under these authorizations, with the final report 
being published in July 2017. EMP Commission members have generally presented HEMP risk to 
critical infrastructure as posing an existential threat to the United States—a position that appears 
to have informed policy in some instances. According to a former senior Commission staff 
member, the EMP Commission informed development of Executive Order (E.O.) 13865, 
“Coordinating National Resilience to Electromagnetic Pulses,” which—he claimed—sought to 
implement the EMP Commission’s core recommendations “on an accelerated basis.”32  
Executive Order (E.O.) 13865 and the FY2020 NDAA 
Table 2 summarizes EMP resilience provisions in Section 1740 of the National Defense 
Authorization Act for Fiscal Year 2020 (FY2020 NDAA; P.L. 116-92) derived from E.O. 13865, 
and the current status of mandated programs and activities.33 In 2020, DHS published an update 
on steps taken to comply with E.O. 13865, and indicated it would conduct additional vulnerability 
testing of “prioritized critical infrastructure components” and validation testing of mitigation 
options “as funding becomes available.”34 
                                                 
default/files/publications/18_1009_EMP_GMD_Strategy-Non-Embargoed.pdf. 
31 Ibid., p. 5. 
32 Peter Pry, “Finally, a Presidential EMP Order That May Save American Lives,” 
The Hill, March 28, 2019, 
https://thehill.com/opinion/national-security/436224-finally-a-presidential-emp-order-that-may-save-american-lives/; 
and Executive Office of the President, “Coordinating National Resilience to Electromagnetic Pulses,” 84
 Federal 
Register 12041, March 26, 2019, https://www.federalregister.gov/d/2019-06325. 
33 The Cybersecurity and Information Security Agency, a DHS agency, maintains an EMP/GMD information page with 
an overview of departmental activities and program updates at https://www.cisa.gov/emp-gmd.  
34 Department of Homeland Security, 
Electromagnetic Pulse (EMP) Program Status Report, August 17, 2020, p. 3, 
https://www.cisa.gov/sites/default/files/publications/emp-program-status-report_508.pdf. 
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Table 2. EMP/GMD-Related Requirements in FY2020 NDAA 
Department or 
Agency 
Requirement 
Deadline 
Status 
Agencies supporting 
Update operational plans 
March 20, 2020 
DOE stated that its 
National Essential 
to protect against and 
updated “response plans, 
Functions 
mitigate effects of 
programs and procedures 
EMP/GMD on critical 
and operational plans all 
infrastructure. 
account for the effects of 
EMP and GMD.”  
DHS (with relevant 
Conduct R&D to improve  March 26, 2020 
DHS developing EMP risk 
sector risk management 
EMP/GMD effects 
models, and protection 
agencies) 
modeling and resilience-
and mitigation 
enhancing technologies. 
technologies for identified 
Submit R&D Action Plan 
high-risk infrastructure 
to Congress to address 
categories. 
shortfalls. 
DHS (with DOD, DOE, 
Complete intelligence-
March 26, 2020 
DHS refining risk models 
DOC) 
based Quadrennial Risk 
to support completion of 
EMP/GMD Assessment 
initial quadrennial 
(QRA) and brief to 
assessment. Initial 
Congress. Use results to 
prioritization of “limited 
increase critical 
set of systems, networks, 
infrastructure resilience, 
and assets” complete, 
prioritizing assets at 
focusing on Energy and 
greatest risk. 
Communications sectors. 
DHS  
Distribute information on 
June 19, 2020 
Ongoing through existing 
EMP/GMD to federal, 
programs and activities. 
state, local, and private 
DHS may create program 
sector stakeholders. Brief 
office to guide public-
to Congress. 
private engagements.  
FEMA (with CISA, DOE, 
Coordinate EMP/GMD 
June 19, 2020 
Ongoing compliance via 
FERC) 
response and recovery 
existing plans and 
plans and procedures. 
procedures—e.g. FEMA 
Power Out Incident 
Annex, and DHS EMP 
resilience guidelines. 
DHS (with S&T, CISA, 
Pilot test of engineering 
September 22, 2020 
Under contract with Los 
FEMA, DOD, DOE) 
approaches to mitigate 
Alamos National 
EMP/GMD effects on 
Laboratory (LANL) for 
critical infrastructure. 
completion by July 2021. 
DHS S&T released report 
on EMP mitigation best 
practices in August 2022. 
DOD (with DHS, DOE) 
Pilot test of engineering 
September 22, 2020 
Interagency pilot project 
approaches to harden 
in San Antonio, TX, 
defense installations and 
ongoing. Additional work 
associated infrastructure. 
pending completion of 
LANL pilot test of 
engineering approaches. 
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Department or 
Agency 
Requirement 
Deadline 
Status 
DHS (with sector-
Review test data on 
December 20, 2020 
No information provided. 
specific agencies, DOD, 
EMP/GMD effects on 
DOE)
 
critical infrastructure to 
identify gaps. Within 180 
days of review, develop 
integrated cross-sector 
plan using public-private 
partnerships to address 
identified data gaps. 
DHS (with DOD, DOE)
 
Report to Congress on 
December 21, 2020 
DHS developed 
technological options to 
technology scouting 
increase critical 
report for confidential 
infrastructure resilience 
distribution to federal 
to EMP/GMD events and 
agencies and designated 
identify gaps and 
private sector partners. 
opportunities, with 
Draft of report to 
updates on quadrennial 
Congress on 
basis. 
technological options in 
review.  
FEMA (with CISA, DOE, 
Conduct EMP/GMD 
December 21, 2020 
Completed in December 
FERC) 
national exercise. 
2020 
DHS (with FEMA, CISA, 
Report to Congress on 
December 21, 2020 
Vulnerability assessment 
DOD, DOC, FCC, DOT) 
effects of EMP/GMD on 
of priority infrastructure 
communications 
ongoing (scheduled 
infrastructure with 
completion July 2021). 
recommendations for 
Report was expected 
changes to operational 
January 2022. 
response plans. 
FEMA 
Maintain relevant 
December 21, 2020 
Complied via briefing to 
emergency alerting 
House Energy and 
systems. Brief Congress 
Commerce Committee 
on state of emergency 
on November 2, 2020. 
notification systems. 
FEMA has hardened some 
key emergency 
communications facilities. 
Source: FY2020 NDAA (P.L. 116-92), Section 1740; email correspondence on March 8, 2021, with James Platt, 
Strategic Defense Initiatives, EMP/PNT/GMD Space Weather/Space Risks, National Risk Management Center, 
CISA; Department of Homeland Security, Electromagnetic Pulse (EMP) Program Status Report, August 17, 2020, 
and CRS search of public sources, 2022. 
Notes: The DHS strategy anticipated E.O. 13865, stating “wil  adjust etc.” Parentheses in the first column 
denote a coordination requirement for the lead department or agency (in bold). CISA = Cybersecurity and 
Infrastructure Security Agency (a part of DHS); DHS = Department of Homeland Security; DOC = Department 
of Commerce; DOD = Department of Defense; DOE = Department of Energy; DOT = Department of 
Transportation; EMP = electromagnetic pulse; FCC = Federal Communications Commission; FEMA = Federal 
Emergency Management Agency (a part of DHS); FERC = Federal Energy Regulatory Commission (an 
independent regulatory commission within DOE); GMD = geomagnetic disturbance; R&D = research and 
development; S&T = Science and Technology Directorate (a part of DHS). 
 
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Not included in the FY2020 NDAA is the E.O. 13865 requirement for DHS and other federal 
agencies to “identify regulatory and non-regulatory mechanisms, including cost recovery 
measures” for private sector entities to address EMP risk.35  
HEMP and Infrastructure Legislation in the 117th Congress  
The IIJA contains several infrastructure resilience provisions that either explicitly include 
addressing HEMP as a program consideration or implicitly allow addressing HEMP as part of an 
all-hazards risk management approach. Other provisions confine funding to extreme weather, 
wildfire, and natural disasters, but nevertheless may still affect HEMP resilience incidentally. For 
general information on IIJA grid resilience provisions, see CRS Report R47034, 
Energy and 
Minerals Provisions in the Infrastructure Investment and Jobs Act (P.L. 117-58), coordinated by 
Brent D. Yacobucci. 
IRA does not contain HEMP-specific provisions. However, changes in grid technology and 
topology envisioned under the law—such as increased use of renewable energy sources—may 
affect HEMP resilience incidentally. For general information on relevant IRA programs, see CRS 
Report R47262, 
Inflation Reduction Act of 2022 (IRA): Provisions Related to Climate Change, 
coordinated by Jane A. Leggett and Jonathan L. Ramseur. 
HEMP-Specific Provisions in the IIJA 
Section 40125(d), “Modeling and Assessing Energy Infrastructure Risk,” authorized $50 million 
over five years for creation of an “advanced energy security program” within DOE to support 
modeling of risks to energy networks posed by natural and human-made threats and hazards, 
“including electromagnetic pulse and geomagnetic disturbance.”36 EMP and GMD are the only 
hazards specifically named under this provision. Examples of eligible activities include 
development of new capacities to identify vulnerable grid components, research on grid 
hardening solutions, research mitigation and recovery solutions, grid resilience exercises and 
assessments, and “technical assistance to States and other entities for standards and risk analysis.” 
Section 40103(d), “Energy Infrastructure Resilience Framework,” directs the Secretary of Energy, 
in collaboration with the Secretary of Homeland Security, FERC, NERC, and “interested energy 
infrastructure stakeholders,” to research options for building and stockpiling portable replacement 
LPTs. In 2017, DOE published a plan in compliance with a similar congressional mandate 
enacted under Section 61004 of the Fixing America’s Transportation Act (P.L. 114-94) to 
establish a strategic transformer reserve in partnership with industry stakeholders.37  
Section 40321, under Subtitle C, “Nuclear Energy Infrastructure,” requires DOE to submit a 
report to Congress on micro and small nuclear reactors. The mandated report must describe how 
the department could enhance energy resilience of DOE facilities and remote communities using 
micro-reactors and small modular reactors, and include an assessment of how such installations 
                                                 
35 
Federal Register, op cit., p. 12045. 
36 Division J of IIJA appropriated funds for this and certain other programs listed in this report. For appropriations 
information on IIJA energy sector programs, see CRS Report R47034, 
Energy and Minerals Provisions in the 
Infrastructure Investment and Jobs Act (P.L. 117-58), coordinated by Brent D. Yacobucci. 
37 Department of Energy, 
Strategic Transformer Reserve, Report to Congress, Washington, DC, March 2017, 
https://www.energy.gov/sites/default/files/2017/04/f34/Strategic%20Transformer%20Reserve%20Report%20-
%20FINAL.pdf.  
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might address the “need for protection against cyber threats and electromagnetic pulses,” among 
other threats and hazards.  
IIJA appropriated $157.5 million under the “Science and Technology Directorate, Research and 
Development” heading, available until September 30, 2026, to the DHS Science and Technology 
Directorate (S&T) for CISR-related “research, development, test, and evaluation.” EMP and 
GMD resilience capabilities were one of five named eligible categories for use of funds.38  
Other Potentially Relevant IIJA Grid Resilience Provisions  
Section 40101, “Preventing Outages and Enhancing the Resilience of the Electric Grid,” 
authorized $5 billion in grant programs for electricity infrastructure owners and operators to 
protect the grid against “disruptive events”—defined as extreme weather, wildfire, or natural 
disaster occurrences that result in preventive or accidental outages, or hazardous safety 
conditions. Eligible activities include construction of microgrids and battery storage equipment, 
installation of adaptive protection technologies, replacement of power lines and underground 
cables, and hardening of power lines, facilities, substations, and other systems.  
Section 40102, “Hazard Mitigation Using Disaster Assistance,” amended the Robert T. Stafford 
Disaster Relief and Emergency Assistance Act (Stafford Act; 42 U.S.C. 5170c (f)(12)) to make 
installation of fire-resistant wires and undergrounding of wires eligible for Stafford Act funding. 
(Undergrounding wires may provide some attenuation of HEMP hazards; see the 
“Undergrounding Electrical Equipment and Power Lines” section.) 
Section 40103 authorized $5 billion to support a new DOE program, “Upgrading Our Electric 
Grid and Ensuring Reliability and Resilience,” which would offer competitive grants for states, 
tribes, local governments, and public utility commissions. Grants would fund technology 
demonstration projects related to resilience and reliability of the electric grid. The provision does 
not name specific threats or hazards. As of this writing, DOE has issued a request for information 
seeking information from stakeholders and a draft funding opportunity announcement.39  
Section 40106, “Transmission Facilitation Program,” authorized programs to increase 
transmission capacity, connect isolated microgrids to infrastructure, and support adoption of 
advanced technologies to increase “capacity, efficiency, resiliency, or reliability of an electric 
power transmission system.” 
Section 40107, “Deployment of Technologies to Enhance Grid Flexibility” authorized $3 billion 
in funds for the DOE Smart Grid Investment Matching Grant Program. Authorized activities 
include buildout of fiber and wireless broadband communication networks, and advanced 
transmission technologies and sensors, to enable better coordination of grid operations and 
enhance grid flexibility. (This includes the ability to island sections of the grid to isolate against 
cascading grid failures in case of extreme weather and nature disasters.) Grid flexibility is a 
power system’s capacity to dynamically balance power supply with demand across a wide area 
using networked systems of electricity generation, transmission, and distribution. 
                                                 
38 The other four categories were (1) special event risk assessments rating planning tools; (2) positioning, navigation, 
and timing capabilities; (3) public safety and violence prevention to evaluate soft target security, including countering 
improvised explosive device events and protection of U.S. critical infrastructure; and (4) research supporting security 
testing capabilities relating to telecommunications equipment, industrial control systems, and open source software. 
39 See DOE, “Program Upgrading Our Electric Grid and Ensuring Reliability and Resiliency,” https://www.energy.gov/
bil/program-upgrading-our-electric-grid-and-ensuring-reliability-and-resiliency.  
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Section 40108, “State Energy Security Plans” amends the Energy Policy and Conservation Act of 
1975 (P.L. 94-163; EPCA) to modify requirements for state energy security plans. Plans must 
address all energy sources and providers, include a state energy profile, address cyber and 
physical vulnerabilities, provide a risk assessment, and provide a risk mitigation approach, among 
other requirements, in order to receive federal financial assistance under Part D of EPCA. The 
program provides grants to support implementation of state energy plans.40 Congress appropriated 
$500 million for formula grants to be awarded under the State Energy Program between FY2022 
and FY2026.41 
Section 40125, “Enhanced Grid Security,” authorizes $250 million over five years for 
cybersecurity-related projects, and to support all-hazards based risk assessments of 
communications, control systems, and power systems architectures used to operate the grid. 
Additionally, it supports pilot projects with energy sector stakeholders to gain experience using 
relevant emerging technologies.  
Section 11105, “National Highway Performance Program,” allows for undergrounding “public 
utility infrastructure” in conjunction with otherwise eligible transportation projects authorized 
under the National Highway Performance Program (23 U.S.C. 119).  
Research Issues 
Issues of scientific theory, method, and analysis continue to be debated within the broader 
research community in response to emerging HEMP research and related policy initiatives. To 
date, research programs—each with its own objectives, assumptions, resources, and limitations—
have generally produced inconsistent or incomplete estimates of HEMP-related risks to 
infrastructure. As such, existing research has failed to elicit broad industry consensus on the 
methods, scale, and scope of any broad-based hazard mitigation program.  
HEMP Environments and Benchmarks 
Non-defense research generally relies upon a limited number of unclassified models of 
electromagnetic hazard fields generated by HEMP—usually referred to as HEMP 
environments—to assess the potential effects of high-altitude nuclear detonations. Unclassified 
HEMP environments, such as the one represented graphically i
n Figure 2, provide the predicted 
peak strength of hazard fields in a given location in relation to the blast epicenter based on a 
generic waveform, but do not provide the fidelity needed to inform comprehensive and 
authoritative risk assessments, according to researchers.  
For example, the EPRI study states, “several unclassified E1 EMP environments exist, but in 
general, these environments have limited usability because they are comprised of a single 
waveform or ... provide a generic representation of the peak electric field on the ground,” and do 
not include other important parameters, such as polarization of the electric field and angle of 
incidence.42 Researchers must then make educated assumptions about these parameters in order to 
                                                 
40 See DOE, “State Energy Program Guidance,” https://www.energy.gov/eere/wipo/state-energy-program-
guidance#bipartisan; and National Association of State Energy Officials, 
NASEO’s State Energy Planning Guidelines: 
Guidance for States in Developing Comprehensive Energy Plans and Policy Recommendations, Arlington, VA, 2018, 
p. 18, https://naseo.org/Data/Sites/1/sepguidelines_2018_final.pdf.  
41 DOE, 
State Energy Program Notice 22-03, Washington, DC, August 26, 2022, p. 2, https://www.energy.gov/sites/
default/files/2022-08/SEP_IIJA_Application_Instructions.pdf. 
42 EPRI study, p. 2-1. See also Ross Guttromson, Craig Lawton, and Matthew Halligan, et al., 
Electromagnetic Pulse—
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predict effects on exposed infrastructure systems. (See the “Obstacles to Improved Risk 
Management” section.) Detailed findings and data from classified EMP research are generally not 
available outside the defense research community. In its final report, the EMP Commission 
criticized Department of Defense (DOD) data classification policies and the “absence of 
technology transfer and other support” to other agencies and critical infrastructure stakeholders.43  
In a January 2021 memorandum, the Secretary of Energy released benchmark waveforms to 
inform testing and predictive modeling by industry and government entities in fulfillment of E.O. 
13865.44 The memorandum did not provide specific hardening standards or “specify the level of 
risk critical infrastructure faces from HEMP.”45 As such, the Secretary presented it as “a first step 
in a long conversation with civilian stakeholders to begin to understand the threat, consequence, 
and risk associated with EMPs and how to address the risks.”46  
The benchmark waveforms published in the memorandum were based on available unclassified 
research from the International Electrotechnical Commission (IEC), Oak Ridge National 
Laboratory (ORNL), and the EMP Commission. The provided peak field strengths for E1 and E3 
electric fields were as follows: 
  E1: 50 kV/m (Source: IEC) 
  E3A: 80 V/km (Source: EMP Commission) 
  E3B: 50 V/km (Source: IEC) 
The DOE memorandum indicated that the benchmark values it provides were provisional, and 
that testing against these benchmarks may “exceed DOE’s currently assessed threat levels by a 
factor of 2 due to predictive modeling uncertainties and potential excursions in HEMP 
environment levels.” Further, “The recommended E1, E2, and E3 HEMP environment benchmark 
waveforms will be updated as necessary, based on further developments in our understanding of 
HEMP generation and modeling and simulation phenomenology.”47  
Modeling and Simulation of Infrastructure Resilience 
Modeling and simulation are used to estimate risk levels to infrastructure in a given HEMP 
environment. Although straightforward in principle, the integration of modeling, simulation, and 
experimental testing of system components to identify and measure relevant risk factors is 
complex in practice.  
                                                 
Resilient Electric Grid for National Security: Research Program Executive Summary, Sandia National Laboratories, 
SAND2020-11227, Albuquerque, NM, October 2020, p. 11, for discussion of waveform limitations and research 
implications. According to the study, available unclassified waveforms from IEC commonly used in non-military 
HEMP risk assessments “lack additional details that, if included in the analysis, would often result in a lesser 
consequence,” p.13. The report provides an overview of a three-year internally-funded research program to investigate 
HEMP and the electric power grid that produced 23 reports and papers. 
43 EMP Commission Executive Report, pp. 8- 9. 
44 Dan Brouillette, 
Physical Characteristics of HEMP Waveform Benchmarks for Use in Assessing Susceptibilities of 
the Power Grid, Electrical Infrastructures, and Other Critical Infrastructure to HEMP Insults, Department of Energy, 
National Security Council Records, Washington, DC, January 11, 2021, https://www.energy.gov/sites/default/files/
2021/01/f82/FINAL%20HEMP%20MEMO_1.12.21_508.pdf. 
45 Ibid., p. 1. 
46 Ibid. 
47 Ibid., p. 2. 
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Modeling and simulation studies must account for one or more of the following:  
  interaction of radiation and blast effects of the weapon with the natural 
environment to produce HEMP hazard fields, 
  interaction of HEMP hazard fields with exposed infrastructure systems and 
assets, and  
  secondary or cascading effects of such interactions on critical infrastructure 
functions.  
Researchers have used modeling and simulation to create and test synthetic electrical grids 
against notional HEMP events, but—absent data on specific system topologies and other sources 
of uncertainty—such tests can produce only general insights on grid behavior and failure 
modes.48 According to EPRI, “Interconnection scale modeling requires a high-fidelity E1 EMP 
environment (not publicly available) and ability to perform coupling calculations on 1000’s of 
substations simultaneously.”49  
Studies using a variety of research designs and methods have produced scientific advancement 
and limited consensus in some areas. However, widely divergent results and assessments of 
HEMP risk to critical infrastructure has highlighted a need for further research and 
methodological advancement.  
Summary of HEMP Research Results  
Despite significant gaps, existing HEMP research has identified several issues of concern that E1 
radiative and conductive threats both present hazards to unprotected DPR, DCS, and supervisory 
control and data acquisition (SCADA) systems in control houses or generation facilities, 
according to some studies.50 (Older electromechanical relays, which have largely been supplanted 
by DPRs, have been found to be highly resistant to electromagnetic pulses.)51 However, 
conductive threats generally present higher risk. Relatively simple (and inexpensive) mitigations, 
such as use of shielding, grounding, and insulation of control lines, as well as modification of 
control house design and materials, appear to significantly reduce—but not eliminate—
vulnerability to E1 hazards.52  
LPTs may suffer physical damage from both E1 and E3 hazards, although estimates of likely 
damage vary. The EMP Commission warned of LPT hotspot heating caused by E3 induced core 
saturation and system harmonics on sufficient scale to render major grid interconnections 
inoperable for months or longer. More recent studies by EPRI and ORNL predicted that such 
losses would occur on a lesser scale and would likely not present a systemic hazard to grid 
operations—assuming that control and communications systems remained operable, and other 
grid equipment was undamaged.53  
                                                 
48 Brian Pierre, Daniel Krofcheck, and Matthew Hoffman, et al., 
Modeling Framework for Bulk Electric Grid Impacts 
from HEMP E1 and E3 Effects, Sandia National Laboratories, EMP-Resilient Grid Grand Challenge: Task 3.1 Final 
Report, Albuquerque, NM, January 2021, p. 35, https://www.osti.gov/servlets/purl/1764794. 
49 Randy Horton, “EPRI Electromagnetic Pulse Research,” Presentation to NERC EMP Task Force Meeting, 
Washington, DC, June 12, 2019, p. 8, https://www.nerc.com/pa/Stand/EMPTaskForceDL/EPRI%206-12-19.pdf.  
50 For example, EPRI study, EMP Commission critical infrastructure report, and EIS study.  
51 EMP Commission critical infrastructure report, p. 24.  
52 For example, EPRI study, EMP Commission critical infrastructure report, and EIS study. 
53 EPRI study, p. xi; and ORNL, op cit., p. 4.  
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Several studies identify voltage collapse caused by E3B as being of generally greater concern 
than heat damage to a large number of transformers.54 Experts predict that in the case of an 
interconnection-scale voltage collapse, restoration would be a complex and lengthy process. Lack 
of availability of utility-scale power adjacent to affected areas and functioning communications 
between geographically dispersed system operators might pose significant challenges.55  
The vulnerability of generation facilities to HEMP threats is a topic of concern. Preliminary field 
testing of a working generation facility by EIS found that E1 threats “will likely disrupt or 
damage typical power plants.”56 The EPRI report stated, “Additional research is needed to 
evaluate the potential impacts of HEMP on generation facilities themselves,” and suggested 
extending the existing mitigation framework for the transmission system to develop hardening 
and mitigation options for generation facilities.57 Additionally, the increasing prevalence of 
renewables may offer both additional resilience and potential vulnerabilities. These technologies 
are rapidly evolving, and research on potential HEMP vulnerabilities is in its preliminary stages 
(see the 
“Inverter-Based Resources” section).  
The Foundation for Resilient Societies, a critical infrastructure resilience research and advocacy 
organization, published a report in 2020 that highlighted vulnerabilities of communications 
technologies used to control electricity generation, transmission, and distribution.58 For example, 
non-conductive fiber optic lines used for communications between electricity grid substations 
rely upon amplifier points—placed at roughly 80 mile intervals—and fiber transceivers at 
substations and control rooms. Fiber optic amplifiers and transceivers are vulnerable to HEMP, 
according to the report.59 Similar risk exists where grid operators use wireless communications to 
control grid assets—often in inaccessible areas where fiber optic technology is cost-prohibitive. 
Wireless communications assets, such as cell towers, are protected against routine 
electromagnetic interference, but may be vulnerable to HEMP.60  
Appendix A provides a summary of selected research products.
 
Emerging Science and Technology Policy Issues 
Major infrastructure legislation enacted during the 117th Congress funds buildout of infrastructure 
capacity, research and planning activities, risk management activities, and expanded use of 
emerging renewable energy technologies in the electricity sector. As of this writing, 
implementation of authorized programs is in its early stages, and any eventual impact on HEMP 
resilience is unknown. The following sections highlight certain technologies supported via 
congressional authorizations and appropriations enacted under IIJA and IRA (see 
“HEMP and 
                                                 54 For example, Ross Guttromson, Craig Lawton, and Matthew Halligan, et al., op cit., p. 15. 
55 EMP Commission critical infrastructure report, p. 31.  
56 EIS study, p. 123. 
57 EPRI study, 8-1; in 2019, EPRI announced new project to evaluate E1 EMP impacts to generation facilities. See 
Edison Electric Institute, “EPRI EMP Report & Grid Security: Key Messages,” press release, April 2019, 
https://www.eei.org/-/media/Project/EEI/Documents/Issues-and-Policy/EPRI-EMP-Report—Grid-Security—Key-
Messages.pdf, p. 2. 
58 See David Winks, 
Protecting U.S. Electric Grid Communications from Electromagnetic Pulse, The Foundation For 
Resilient Societies, Exeter, NH, May 2020.  
59 Ibid., p. 4.  
60 Ibid. 
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Infrastructure Legislation in the 117th Congress” section) that may have implications for HEMP 
resilience depending upon implementation policies.  
Inverter-Based Resources 
Wind, solar, fuel cells, and batteries make up an increasing share of power generation and supply 
capacity. These power sources use inverters to convert the direct current electricity they produce 
to alternating current electricity used by most electricity consumers. Wind resources are usually 
implemented on utility-scale. Solar and battery resources may be implemented at utility-scale to 
provide power for the grid, or may be used for rooftop and residential applications as distributed 
energy resources (DERs). Hybrid approaches use digital control systems to combine DERs 
operating as virtual power plants with grid-scale generation assets. Development and deployment 
of such systems is in its early stages, as of this writing.61  
The comparative advantages or disadvantages of distributed or hybrid generation using inverter-
based resources to provide energy and grid services during a HEMP event have not yet been 
extensively researched.62  
A 2022 National Renewable Energy Laboratory (NREL) study on hybrid power plants and grid 
resilience suggested that “hybridizing or spatially distributing renewable energy generation 
assets, the complementarity of the distinct resources can be leveraged to provide energy and grid 
services more reliably than any of the assets can on their own.”63 However, it did not examine 
potential effects of HEMP on inverter-based resources or associated electronic control systems 
necessary to administer and provide operational control of hybrid power plants. The 2019 EPRI 
report states that resilience of inverter-based generation against E1 hazards is unknown. Other 
preliminary research indicates that photovoltaic panels are highly resistant to E1, but more testing 
of connected inverters and associated electronic control systems is necessary.64  
Inverter-based resources can provide ancillary services to the electricity grid such as voltage 
support to help maintain stability if designed and configured appropriately.65 Electric vehicles—
essentially batteries on wheels—equipped with vehicle-to-grid (V2G) technology may provide 
the same grid services, but the relevant technologies to automatically aggregate and coordinate 
charging and power dispatch are still in the development and planning stages.66 Existing research 
and development largely focuses on the routine application of battery storage and V2G 
                                                 
61 For example, see Miranda Wilson, “Northeast Embraces First-of-a-Kind Virtual Power Plant,” 
E&E News, October 
12, 2022, https://www.eenews.net/articles/northeast-embraces-first-of-a-kind-virtual-power-plant/. 
62 EPRI study, p. 4-25; and DOE, Wind Energy Technologies Office, “Wind Turbines Can Stabilize the Grid,” May 16, 
20222, https://www.energy.gov/eere/wind/articles/wind-turbines-can-stabilize-grid. 
63 Caitlyn E. Clark, Aaron Baker, and Jennifer King, et al., 
Wind and Solar Hybrid Power Plants for Energy Resilience, 
National Renewable Energy Laboratory, NREL/TP-5R00-80415, Golden, CO, January 2022, p. 4, 
https://www.nrel.gov/docs/fy22osti/80415.pdf. 
64 See Tyler Bowman, Jack David Flicker, Ross Guttromson, et al., 2020, “High Altitude Electromagnetic Pulse 
Testing of Photovoltaic Modules,” Sandia National Laboratory, Albuquerque, NM, https://doi.org/10.2172/1614961. 
65 Malcolm Abbott and Bruce Cohen, “Issues Associated with the Possible Contribution of Battery Energy Storage in 
Ensuring a Stable Electricity System,” 
The Electricity Journal, vol. 33, no. 6 (July 2020), pp. 1-6, and CRS Report 
R45980, 
Electricity Storage: Applications, Issues, and Technologies, by Richard J. Campbell.  
66 IIJA Sec. 40414 provides for data collection on electric vehicle integration with the electricity grids to further 
research on V2G applications. For a technical discussion of relevant issues, see Jingyuan Wang, Guna R. Bharati, and 
Sumit Paudyal, et al., “Coordinated Electric Vehicle Charging with Reactive Power Support to Distribution Grids,” 
IEEE Transactions on Industrial Informatics, vol. 15, no. 1 (January 2019).  
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technologies for maintaining grid stability. The utility of these technologies in a HEMP scenario 
is largely unknown.  
Microgrids 
Microgrids may operate independently of the bulk electricity system if they are configured with 
the appropriate hardware and software.67 Microgrids may be powered by a variety of power 
sources and may offer some resilience to connected homes, businesses, and essential facilities 
against large-scale outages caused by HEMP. However, microgrids—especially those intended for 
civilian use—are not necessarily designed to withstand E1 pulses that may affect power control 
systems and other sensitive electronics.68  
Nonetheless, hardening microgrids against HEMP through the use of protective enclosures and 
other measures may be more practical and less costly than for conventional grid assets.69  
By definition, microgrids do not use long transmission lines and LPTs that form the backbone of 
the electric grid, and so they do not have direct vulnerability to GMD caused by E3 when 
operated independently of the grid. Some connected microgrids have the capability to disconnect 
from major distribution networks and operate in “island” mode during an emergency in order to 
avoid cascading effects of large-scale grid failures. 
Transmission Facilitation and Grid Flexibility 
For economic reasons, the existing electricity system operates with minimal redundancy and 
spare capacity—a condition enabled by increased adoption of (potentially vulnerable) electronic 
controls and other digital technologies in recent decades.70 Power grids are more vulnerable to 
disruption when they operate with little spare capacity, according to experts.71 Increased 
transmission capacity provides greater margins for grid operators to manage disruptions and 
provide additional reactive power to maintain system voltages if necessary. A 2019 study by the 
National Renewable Energy Laboratory predicted that considerable growth in electricity demand 
due to anticipated electrification of residential heating and transportation (electric vehicles) would 
“likely require grid capacity expansion and make grid operations and planning more 
challenging.”72 
Infrastructure programs to support increased transmission capacity and grid flexibility may 
remediate these deficiencies to some degree. However, IIJA and IRA infrastructure programs to 
                                                 
67 According to DOE, “A microgrid is a group of interconnected loads and distributed energy resources within clearly 
defined electrical boundaries that acts as a single controllable entity with respect to the grid. It can connect and 
disconnect from the grid to enable it to operate in grid-connected or island-mode.” See Dan Ton, 
Microgrid R&D 
Program at the U.S. DOE, Office of Electricity, Department of Energy, Washington, DC, November 2018, p. 3, 
https://www.energy.gov/sites/prod/files/2018/12/f58/remote-microgrids-dan-ton.pdf.  
68 See George H. Baker, “Microgrids—A Watershed Moment,” 
Insight, vol. 23, no. 2 (2020). 
69 Barry Wilson, 
EMP Hardening with Electric Power Microgrids, Enviropower, Renewable Inc., Boca Raton, FL, 
2019, p. 7, https://eprenewable.com/wp-content/uploads/2019/04/EMP_Hardening-with-Electric-Power-
Microgrids.pdf. 
70 The EMP Commission, 
Report of the Commission to Assess the Threat to the United States from Electromagnetic 
Pulse Attack, Critical National Infrastructures, Washington, DC, April 2008, p. 23.  
71 Ibid., p. 17.  
72 Michael Blonsky, Adarsh Nagarajan, and Shibani Ghosh, et al., “Potential Impacts of Transportation and Building 
Electrification on the Grid: A Review of Electrification Projections and Their Effects on Grid Infrastructure, Operation, 
and Planning,” 
Electrification, vol. 6, November 13, 2019, p. 169, https://link.springer.com/article/10.1007/s40518-
019-00140-5. 
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facilitate integration of inverter-based resources and microgrids into the existing bulk electric 
system focus on environmental performance—i.e., lower carbon dioxide emissions—and 
resilience to extreme weather, wildfires, and natural disasters.  
Future Grid Technologies and HEMP 
 Improvements in grid flexibility may enhance 
the power system’s capacity to dynamically 
New and emerging grid hardware technologies based 
on semiconductor-based, solid state power converters 
balance power supply with demand across a 
may offer a number of broad resilience benefits, 
wide area using networked systems of 
according to DOE. The 2021 DOE technology 
electricity generation, transmission, and 
roadmap for solid state power substations (SPSS) 
distribution during a HEMP event, if only 
envisions replacement of existing analog grid substation 
incidentally. However, potential operational 
equipment with solid state technology.73  
benefits and resilience of such prospective 
Eventually, such systems might enable a grid that is 
“ful y asynchronous, autonomous, and fractal”—i.e., 
systems to HEMP—many of which are still in 
able to operate without frequency synchronization at 
the research and development phase—are 
the interconnection level; less reliant on long-distance 
largely unknown.74 Loss of grid flexibility 
communications networks for operational control; and 
during a HEMP event may complicate efforts 
able to rapidly isolate grid components to prevent 
to manage disruptions and maintain 
cascading failures.  
functioning power supply. Existing HEMP 
Solid state technologies may also help emergency 
recovery by providing more portable and 
research has largely focused on hazards to 
interchangeable designs for major electric substation 
conventional grid operations, rather than 
components. Such grid technology features have long 
inverter-based resources, microgrids, and 
been of interest to the HEMP policy and research 
advanced transmission technologies (see the 
community, given the risks of system-level impacts 
section 
“Modeling and Simulation of 
from a HEMP event.  
Infrastructure Resilience”).  
However, successful commercialization of relevant 
technologies may be decades away in some cases. 
Additionally, their resilience to HEMP threats is largely 
Undergrounding Electrical 
unknown.  
According to the DOE technology roadmap, “The 
Equipment and Power Lines 
ability to withstand electromagnetic interference (EMI) 
and 
electromagnetic pulses [emphasis added] are . . areas 
IIJA funds for undergrounding electrical 
of investigation that wil  need to span the entire 
equipment and power lines are restricted to 
converter architecture, including the control ers and 
protection against extreme weather, wildfires, 
communication subsystems.” 
and natural disasters (see 
“Other Potentially 
Relevant IIJA Grid Resilience Provisions”). 
However, undergrounding certain assets to protect against these hazards may incidentally affect 
HEMP resilience. EPRI research showed that undergrounding control cables at substations 
connected to DPRs provided significant equipment protection against simulated E1 pulses.75 In 
the case of buried long-distance transmission lines, conductive earth may attenuate early-time E1 
pulses—lessening any coupling hazards to the grid. However, undergrounding long-distance 
transmission lines would not prevent GIC caused by E3 magnetohydrodynamic effects, which 
propagate through conductive geologic formations underground and enter the grid through 
transformer groundings.  
                                                 
73 See Department of Energy, Office of Electricity, 
Solid State Power Substation Technology Roadmap, Transformer 
Resilience and Advanced Components Program, Washington, DC, June 2020, p. 31, https://www.energy.gov/oe/
downloads/solid-state-power-substation-technology-roadmap. 
74 Ibid., p. 31. 
75 EPRI study, p. 4-10. 
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Issues for Congress 
As of this writing, DHS and other relevant federal agencies continue to implement legislative 
mandates contained in the FY2020 NDAA, which legislate many of the directives contained in 
E.O. 13865 (see the 
“Executive Order (E.O.) 13865 and the FY2020 NDAA” section). Major 
outstanding items include DHS risk models for critical infrastructure and associated risk 
assessments, engineering approaches for risk mitigation, and identification of emerging EMP 
protection technologies. Many mandated deadlines have already passed. Documents submitted by 
other agencies in compliance with E.O. 13865, such as the DOE memorandum on HEMP 
waveforms (see the 
“HEMP Environments and Benchmarks” section) present data from existing 
sources that are more than a decade old in some cases, and contain caveats indicating uncertainty.  
It is not clear that existing HEMP research is sufficiently mature for DHS, or any other federal 
agency, to provide authoritative guidance to policymakers or industry stakeholders on 
prioritization of critical systems and assets for hardening or other countermeasures in the near 
future. DHS has indicated more funding would be necessary to support necessary research (see 
the 
“Executive Order (E.O.) 13865 and the FY2020 NDAA” section). IIJA appropriations to 
federal agencies may support further research, depending upon how funds are apportioned to 
specific research programs by implementing agencies (see the 
“HEMP-Specific Provisions in the 
IIJA” section).  
In all these potential HEMP-related issues, the appropriate roles for federal agencies, states, and 
the private sector would be fundamental areas for congressional consideration. 
Obstacles to Improved Risk Management 
Researchers consistently identify issues with the underlying quality of data used to model HEMP 
risk to critical infrastructure (see the 
“HEMP Environments and Benchmarks” section) as an 
obstacle to providing more authoritative risk assessments to critical infrastructure stakeholders. 
The EMP Commission and others have suggested that improved access to DOD and 
DOE/National Nuclear Security Administration data and research on electromagnetic effects of 
nuclear weapons, and selective declassification of certain data and research, might reduce such 
obstacles, if only to a degree. Congress may consider legislating parameters and specific 
objectives of interagency cooperation between DOD, DHS, DOE, and other relevant federal 
agencies, and provide funding and oversight as appropriate.  
Researchers also note the need for more detailed modeling of underground geologic formations 
that play a role in propagation of E3 related hazards, and more detailed knowledge of specific 
infrastructure topologies that affect system-level resilience to HEMP (see the 
“Modeling and 
Simulation of Infrastructure Resilience” section). The U.S. Geological Survey, an agency of the 
Department of the Interior, administers a geomagnetism program that supports the National Space 
Weather Strategy, which focuses on naturally occurring electromagnetic hazards similar to 
manmade E3. The program received increased funding under the FY2020 appropriations act to 
continue a national magnetotelluric survey started by other federal agencies.76 Congress may 
consider exercising oversight and other authorities to ensure relevant findings are available to the 
HEMP research community. 
Similarly, Congress may consider exercising oversight of existing DHS administered partnerships 
with critical infrastructure stakeholders for protected critical infrastructure information disclosure 
                                                 
76 See CRS In Focus IF11181, 
The U.S. Geological Survey (USGS): FY2020 Appropriations Process and Background, 
by Anna E. Normand. 
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and information sharing, such as the Protected Critical Infrastructure Information program, which 
may assist DHS in completing HEMP risk management activities mandated by the FY2020 
NDAA (see the 
“The CISR Framework and HEMP” section).  
Incentivizing and Facilitating Investment in HEMP Resilience 
E.O. 13865 contemplates future introduction of cost-recovery mechanisms (such as increased 
consumer electricity rates) that certain electricity providers could use to fund HEMP resilience 
investments. In September 2022, FERC released a Notice of Proposed Rulemaking (NOPR) to 
provide “incentive-based rate treatment” for utilities that invest in “advanced cybersecurity 
technology” and participate in cybersecurity threat information sharing programs, pursuant to 
Congress’s instructions in IIJA.77 The NOPR suggests certain cost-recovery mechanisms that may 
be further elaborated during the rulemaking process. Congress may wish to direct FERC to 
develop a similar rule to incentivize investment in HEMP resilience. Development and 
implementation of such a rule might depend in part on availability of improved risk models, risk 
assessments, and mitigation technologies as described above. 
Congress may consider exercising oversight of development and implementation of State Energy 
Security Plans described in Section 40108 of the IIJA (see the “Other Potentially Relevant IIJA 
Grid Resilience Provisions” section) to ensure that HEMP resilience considerations are included 
as deemed appropriate. DOE administers the program at the federal level and reviews and 
approves individual state plans based on compliance with IIJA statutory requirements.78  
Any congressional action would take place in a rapidly changing technology environment as grid 
modernization and hardening initiatives authorized under IIJA, IRA, and other legislation 
proceed, offering both opportunities and risk to policymakers (see the “Emerging Science and 
Technology Policy Issues” section). Inverter-based energy resources and microgrids may 
contribute to grid resilience against HEMP threats if they are appropriately configured and 
located to provide grid services, such as voltage support, and are able to survive the HEMP 
environment. Congress may consider supporting relevant research and development activities 
through legislation, oversight, and appropriations. 
Relevant (functionally identical) technologies may be more or less resilient to HEMP, depending 
on what technical standards are applied to their design and manufacture, and their system 
configuration. Existing legislation primarily contemplates resilience to extreme weather hazards, 
wildfire, and other natural disasters as design considerations (see the 
“HEMP and Infrastructure 
Legislation in the 117th Congress” section). Congress may consider explicit inclusion of HEMP 
resilience in future infrastructure or related grants legislation. Additionally, Congress may 
consider directing FERC to oversee development and implementation of infrastructure protection 
standards specific to HEMP if deemed necessary (see 
“The CISR Framework and HEMP” 
section). 
                                                 
77 See FERC, “FERC Proposes Incentives for Voluntary Cybersecurity Investments,” https://www.ferc.gov/news-
events/news/ferc-proposes-incentives-voluntary-cybersecurity-investments. For a summary of existing threat 
information sharing programs, see CRS In Focus IF12061, 
Critical Infrastructure Security and Resilience: Countering 
Russian and Other Nation-State Cyber Threats, by Brian E. Humphreys. 
78 Department of Energy, Energy Efficiency and Renewable Energy Golden Field Office, 
Administrative and Legal 
Requirements Document, Golden, CO, March 28, 2022, p. 11, https://www.energy.gov/sites/default/files/2022-03/sep-
state-energy-security-plan_alrd.pdf. 
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Future Technological Advancements 
Congress may consider future technological advancements when developing policies relevant to 
HEMP resilience. For example, LPT stockpiling programs considered in the IIJA and previous 
legislation assume existing transformer designs as the basis for operational control of electricity 
transmission and distribution, which require large lead times for manufacture, customization, and 
transport (see the 
“HEMP-Specific Provisions in the IIJA” section). Emerging solid state 
technologies may enable a more rapid and flexible use of standardized systems to support a 
building-block approach to construction and repair of grid infrastructure that would eliminate the 
need for vulnerable LPTs. Likewise, such technology might enhance efficiency without 
increasing risks to grid stability—an improvement over most existing technologies (see “Future 
Grid Technologies and HEMP” text box, p. 20). Congress may consider balancing the need to 
manage risks to existing infrastructure against the possibility of eliminating certain risks through 
adoption of new technologies. Given the long service life of most electricity infrastructure assets, 
it may be appropriate to encourage investment in next-generation technologies where possible to 
avoid inefficient use of limited resources to harden obsolescent technologies against HEMP.  
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Appendix A. Selected Studies by Year 
 
Research 
(year) 
Research Design and Methods 
Results and Conclusions 
SANL (2021) 
Modeling and simulation of E1 and E3 HEMP 
Significant additional modeling and 
hazards to notional bulk electric power grid. 
simulation work on interaction of 
(Effects of E3 harmonics not studied.) Use of 
HEMP environment with grid 
statistical methods and component testing results 
infrastructure needed “to draw realistic 
to quantify transient response of a modeled grid to 
conclusions” on HEMP risk to 
a HEMP event (IEC waveform), including cascading 
infrastructure.  
effects of E1 and E3. 
SANL (10/2020)  Study of conductive threat effects of simulated E1 
Average maximum voltages on 
HEMP events (using IEC waveform) on transmission  overhead transmission lines were lower 
lines and grid equipment control lines. Modeling and  than the “typical worst case.” Induced 
simulation to predict the effects of location and 
voltage on these lines was, on average, 
orientation of conductors relative to HEMP source 
about 55% of the anticipated maximum 
on induced current and voltage, and produce 
value for a worst-case scenario for a 
statistics on peak value, rise time, and pulse width 
given line orientation.  
at a given location. 
SANL (9/2020) 
Testing of electric power substation circuits and 
“No equipment damage or undesired 
certain protective equipment against simulated E1 
operation occurred on the tested 
insult. Injection of simulated E1 pulse into three 
circuits for values below 180 kV, which 
different types of circuits (breaker, potential 
is significantly higher than the 
transformer, and current transformer) connecting 
anticipated [E1] coupling to a 
digital protective relays (DPRs) in a control house 
substation yard cable.” 
with substation yard equipment.  
SANL (4/2020) 
Testing of photovoltaic (PV) modules against 
“No direct failures” of PV modules and 
simulated E1 insult to 100 kV/m benchmark. Does 
only “minor observable module 
not include testing of inverter systems used to 
degradation” fol owing exposure. 
convert direct current (DC) to alternating current 
Testing of inverter systems against 
(AC).  
observed coupled currents planned for 
future research.  
EIS/SARA 
DPR and distributed control system (DCS) 
Unprotected DPRs and DCS 
(2020) 
components subjected to pulsed electric fields and 
components were susceptible to 
pulsed current injection to limits specified by 
simulated HEMP insults. Simple 
military standard (MIL-STD) 188-125. Working 
remediation significantly mitigated risk. 
generating station exposed to simulated HEMP 
Generation station DCS and generator 
hazard fields. Strength of subcomponents tested or 
exciter systems are potential y 
evaluated based on vendor documentation. 
vulnerable. Generation facility easily 
penetrated by simulated E1 fields.  
EPRI (2019) 
Commonly used DPRs subjected to simulated E1 
Conductive E1 threats pose significant 
pulsed electric fields and pulsed current injection 
threat to unprotected DPRs. Simple 
based on MIL-STD-188-125 (up to 50 kV/m). 
remediation significantly mitigates risk. 
Shielding effectiveness tests of typical substation 
E3B may produce regional blackouts 
control houses and mitigation devices. 
due to voltage instability. Wide-scale 
Interconnection-level assessments of E1 effects 
LPT heat damage limited. Recoverable, 
based on LANL (25 kV/m) and IEC 61000-2-9 (50 
assuming limited harmonic effects, and 
kV/m) E1environments, and E3B effects based on 
adequate E1 protection of DPRs, DCS, 
LANL HEMP environment and predicted reactive 
and communications.  
power losses. Effects of harmonics not studied. 
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Research 
(year) 
Research Design and Methods 
Results and Conclusions 
ORNL (2019) 
Assessment of system-wide impact to LPTs of 
E1 may cause rapid voltage surges on 
voltage surges and harmonics caused by HEMP or 
long power lines, bypassing arresters 
GMD. Pulsed electric fields based on IEC E1 
designed to protect LPTs. Risk 
benchmark for stress test of voltage arresters and 
mitigated in some cases by modification 
bushings to validate modeling. Computational 
of system topology and use of updated 
analysis of E1 and E2 effects on transformer 
LPT designs. E3 is a “reduced risk 
windings. E3 effects modeling based on actual grid 
event.” Voltage stability is maintained 
topology to predict GIC impacts on LPT core 
even with significant loss of reactive 
saturation and harmonics generation. Impact of 
compensation units. GIC-blocking 
GIC-blocking devices on grid stability simulated. 
devices on LPTs are best risk-mitigation 
option. 
EMPC (2017) 
Analysis of E3 fields created by two Soviet tests in 
Recommended E3 field strength 
1962. Infrastructure modeling and simulation from 
benchmark of 85 V/km for testing 
2008 study. Protective relays, DCS, and supervisory  purposes. SCADA and—to lesser 
control and data acquisition (SCADA) systems 
degree—DCS most vulnerable. DPRs 
exposed to simulated E1insults via free-field 
comparatively robust. Wide scale and 
il umination and cable current injection. Expert 
long-lasting grid col apse likely in many 
assessment of likely cascading effects of entire 
scenarios. 
HEMP sequence, and restoration considerations.  
Sources: Brian Pierre, Daniel Krofcheck, and Matthew Hoffman, et al., 
Modeling Framework for Bulk Electric Grid 
Impacts from HEMP E1 and E3 Effects, Sandia National Laboratories, EMP-Resilient Grid Grand Challenge: Task 
3.1 Final Report, Albuquerque, NM, January 2021; Richard L. Schiek and Matthew Halligan, 
Statistical Profiles of E1 
EMP Coupling to Single Conductors, Sandia National Laboratories, SAND2020-10738, Albuquerque, NM, October 
2020; Alfred Baughman, Tyler Bowman, and Ross Guttromson, et al., 
HEMP Testing of Substation Yard Circuit 
Breaker Control and Protective Relay Circuits, Sandia National Laboratories, SAND2020-9872, Albuquerque, NM, 
September 2020; Tyler Bowman, Jack Flicker, and Ross Guttromson, et al., 
High Altitude Electromagnetic Pulse 
Testing of Photovoltaic Modules, Sandia National Laboratories, SAND2020-3824, Albuquerque, NM, April 2020; 
Chris Beck, Eric Easton, and Carl Eng, et al., 
Electric Infrastructure Protection Handbook IV: Electromagnetic Pulse 
Protection Best Practices, the Electric Infrastructure Security (EIS) Council, Washington, DC, 2020; Electric Power 
Research Institute (EPRI), 
High-Altitude Electromagnetic Pulse and the Bulk Power System: Potential Impacts and 
Mitigation Strategies, Palo Alto, CA, April 2019; A.G. Tarditi, J.S. Besnoff, and R.C. Duckworth, et al., 
High-Voltage 
Modeling and Testing of Transformer, Line Interface Devices, and Bulk System Components Under Electromagnetic Pulse, 
Geomagnetic Disturbance, and Other Abnormal Transients, Oak Ridge National Laboratory, ORNL/TM-2019/1143, 
Oak Ridge, TN, March 18, 2019; The Commission to Assess the Threat to the United States from 
Electromagnetic (EMP) Pulse Attack, 
Assessing the Threat from Electromagnetic Pulse, Executive Report, 
Washington, DC, July 2017. 
Notes: EIS = EIS Council; EMPC = EMP Commission; EPRI = Electric Power Research Institute; ORNL = Oak 
Ridge National Laboratory; SANL = Sandia National Laboratories; SARA = Scientific Applications and Research 
Associates.  
 
 
 
 
 
 
Congressional Research Service  
 
26 
Ensuring Electricity Infrastructure Resilience Against Electromagnetic Pulse Threats  
 
 
Author Information 
 Brian E. Humphreys 
   
Analyst in Science and Technology Policy     
 
 
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Congressional Research Service  
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