The Department of Energy just received the first round of public comments on their Draft Outline for the Proposed Joint U.S.-Canadian Electric Grid Strategy (“Draft Joint Strategy Outline”). One thorough review, done by Resilient Societies, reported a laundry list of fatal flaws in the methodology and approach that DoE took.
“The outline as proposed omits significant threats and hazards and therefore could devolve into a document that provides false assurance of safety to the public instead of real action.”
A Joint Strategy with Canada is well conceived. The U.S. and Canada share large interconnected sections of the electric grid. The fact that most of Quebec was blacked out by a solar storm in 1989 did not cause DoE to think twice about leaving the threat of solar storms out of the strategy.
Several of the fundamental flaws of the DoE approach were already on display with their joint electromagnetic pulse resilience strategy with the industry trade association EPRI (the Electric Power Research Institute). The first is allowing an industry with a financial interest in not appearing vulnerable for their investors sake to define a risk down. That will result in artificially low safety standards that contradict established risk assessments in the military and by the Congressional EMP Commission. The second is the ‘risk management’ system that DoE and DHS use to give low priority to low frequency events. That approach in other sector specific agencies would allow for lack of preparation for 100 year floods or screening for bombs at the airport due to a lack of frequency of terrorist attacks.
‘Risk Management’ at DOE is a code word for a flawed methodology that cannot secure the electric grid. The code word is used to let the federal government off the hook for allowing the utility industry to down play serious risks and threats. Mitigating real world threats requires a security strategy based on threat analysis. That is something that DOD knows how to do for certain assets. The current ‘risk management’ system relegates the high impact threats to a low priority based on bad math.
This type of management is a symptom of the combination of industry influence and the absence of legal empowerment to create and enforce real safety standards. Watch the public comments closely. There are more groups like Resilient Societies who recognize the dangers inherent in flawed policy leadership.