ing evolving information to the public in view of potential legal ramifications and the responsibility to limit information available to terrorists. A key consideration is avoiding over-reactions by informing the public while providing the highest level of protection to the nation.
Recommendation 7.1 The Department of Energy and the Department of Homeland Security should fund the research, development, manufacture, and deployment of stocks of compact, easily transported, high-voltage restoration transformers for use in temporary recovery following the loss of several to many regular transformers.
Recommendation 7.2 Utilities and federal, state, and local governments, and law enforcement agencies should develop official memoranda of understanding (MOUs). These MOUs should spell out each party’s responsibilities before, during, and immediately following a deliberate destruction of utility equipment that leads to a disruption of electric service; provide a clear understanding of who is in charge; and explain how decisions will be reached in dealing with potential tensions between crime scene investigation and timely service restoration as well as unanticipated contingencies. The MOUs should also help to ensure the appropriate allocation of resources, and address concerns about potential government seizure of utility supplies and equipment during catastrophic events,9 which can seriously hinder prompt utility restoration of electric service.
Recommendation 7.3 State and federal law or regulations should be modified to:
• Recognize utilities as essential service providers so that relevant utility employees can be trained and legally designated as first responders to deal with attacks on the power system.
• Provide utilities, when needed, with temporary exemptions from laws that restrict their use of equipment, access to roads, materials, supplies, and other critical elements for restoration of electric service to essential loads, including those that have an impact on public health and safety.
• Ensure that state regulatory agencies support prudent efforts by utilities to commit and acquire the necessary resources for service restoration and provide reasonable assurance for recovery of these costs.
Recommendation 7.4 The Department of Homeland Security and the Edison Electric Institute should jointly develop programs and offer training for key utility personnel to respond to both conventional security threats and potential chemical/biological attacks on the electric infrastructure. The training should provide increased awareness of the possible threats, through risk assessments, and provide specific training for the use of protection equipment, detection and sensor equipment, and emergency decontamination procedures. Existing drills and restoration procedures must be expanded to address the potential for biological or chemical attacks that would disrupt electric operations and infrastructures.
Recommendation 7.5 The Department of Homeland Security with the Department of Energy and the electric reliability organization should work with utilities that have not yet done so to:
• Establish a team reporting to top management that coordinates physical, cyber, and operations security through comprehensive plans that clearly define what is expected of security personnel before, during, and after a deliberate destructive act; identifies the technologies and strategies to be used to continuously monitor critical company facilities; and establishes an Incident Command System and designates an incident commander to work with outside agencies.
• Examine their internal radio communications systems to determine that battery backup systems and portable generators are in place to ensure that all communication devices will remain operational during a crisis. Because traditional communication systems may become unavailable during a destructive attack on the electric system, options such as satellite communications should be evaluated (and periodically tested) for potential use as backup communication. In addition, the ERO could help ensure that neighboring utilities and operators have compatible communications systems.
• Assess black-start capabilities in their systems under the assumption that major physical disruption of the transmission system can occur, develop appropriate contingency plans, and test both the plans and the equipment on a regular basis.
• Assess the potential for the cascading collapse of long stretches of transmission line, and, where appropriate, include offsetting towers at various intervals or reinforcing or upgrading towers at more frequent intervals along the line.
Recommendation 7.6 State legislatures should change utility law to explicitly allow micro-grids with distributed generation. IEEE should revise its standards to include the appropriate use of islanded distributed generation and micro-grid resources for local islanding in emergency recovery operations. Utilities should reexamine and, if necessary, revise their distribution automation plans and capabilities in
9For example, during Hurricane Katrina there were efforts by some government entities to commandeer some utility communication systems and fuel supplies.