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The time is ripe for the industry to embrace necessary reform measures before we inevitably face a time-critical grid restoration resulting from a
black sky event.

Editor's Note: For more on this topic, consider registering for T&D World's BLACK SKY HAZARDS & GRID RESILIENCE virtual event,
taking place next week, Nov. 16-17.

The Texas power outage of February 2021 is already fading from memory, but observations made by experts at the time, warrant a follow up
discussion. Experienced power grid engineers and utility managers both made statements to the effect that the residents were lucky the entire
Texas grid didn’t go down, because had it done so, restoration would likely have taken many weeks to complete. While that may be true,
particularly considering the complex nature of restoration work and the many threats facing a large centralized grid, such statements absolutely
warrant a few “why” questions.

The purpose of this piece is to start a discussion on the many hidden issues inherent in Black Starting and grid rebuilding, particularly since the
winterization issues that came to light during the Texas incident occurred due to “reality therapy,” not from forethought or proactive action. The
authors’ hope is that through this article, and those others will write, opportunities for utilities to improve response times to major outages will
be brought to light, and acted upon. Specifically, this article will explore the evolution of the grid into its current state and suggest several
opportunities to both reduce risk-exposure and improve restoration time.

By way of background, the power grid infrastructure has experienced many changes over the past 40 years. At a high level, some of the relevant
changes to that landscape have included:

Introduction of non-utility entities as co-generators, characterized by more efficient use of available capital and fuel resources, essentially
using the same fuel to both generate electricity and perform operations integral to their core business mission.
Mixing utility-owned and common carrier-owned telecom systems at the point of core power-generation, transmission, in and balancing
operations. Additionally, the evolution of the balancing network’s telecom infrastructure from slower analog and Time Division Multiplex
communications circuits to high-speed computer-based Internet Protocol (IP).
Shifting the role of utilities from complete responsibility to generate, transmit, and serve customer load, to owner/operators of public
resources under the control of others — such as Balancing Authorities (BAs)and Reliability Coordinators (RCs) and Independent System
Operators (ISOs). In this scenario, much of the utilities’ historical power generation has effectively been spun off to other entities. As a
result, many if not most utilities do not now own enough internal generation capacity to meet their load, but rather are dependent on 3rd
Party generation owners (who may not necessarily share the same moral imperative to serve customer load) to provide resource adequacy.
Creation of regional Independent System Operators (ISOs) that keep generation and load in balance and provide a market-based vehicle to
replace the formerly utility-based reliability function. The ISOs, through the market approach are assumed to provide a more financially
equitable and open forum, allowing many different entities the opportunity to participate in the wholesale electricity market. Additionally,
many ISOs also provide the BA and RA functions as defined under North American Reliability Corporation (NERC) Reliability Standards
approved by the Federal Energy Regulatory Commission (FERC).
The integration of unprecedented amounts of variable and sometimes intermittent solar and wind energy. This “green” energy is often
purchased and coordinated over long distances, increasingly outside the geography of local utilities and Balancing Authority’s direct control.
This approach improves utilities’ ability to meet clean air, water, and greenhouse gas standards in accordance with evolving climate change
requirements. However, considering the sheer complexity of integrating an aggressive renewable resource buildout, one needs to consider
the potentially negative implications for the rapid ramping of conventional generation necessary for proper grid security, particularly using
these resources during grid restoration.
Introduction of national reliability standards by NERC and approved by the United States government ‘s regulatory body, FERC. These
standards are promulgated to generation and transmission operators and establish a minimum level of reliability performance and training
for their organization’s personnel and related equipment. This includes, but is not limited to, aspects of the control systems,
telecommunications and protective relaying used to operate the grid. Each of the following reliability councils within the three major U.S.
interconnections (WECC in the West, ERCOT in Texas, and MISO, SERC, NRP and RF in the East) audit their local grid participants to these
standards every 3 years.
Introduction of increasingly complex, computer-based grid monitoring and protection systems otherwise known as Synchrophaser
Networks (SN), Remedial Action Schemes (RAS), and Advanced Network Real-Time State Estimators (RTSE) that monitor grid conditions
over a wide area and, either invoke significant automatic action, or underpin critical sensitive human decision making, potentially
interrupting or re-direct electrical flows across a wide area. These systems, due to their computer-based control and often IP-dependent
communications are subject to similar security concerns as other Supervisory Control and Data Acquisition (SCADA) type networks.

At this point it is important to stop and appreciate the marvelous complex machine that the many stakeholders within the grid have built, and the
extent to which they have created a system that runs both reliably and economically. In doing so, we need to acknowledge the hard work that
NERC, WECC, local ISOs (CAISO in California), Investor-Owned Utilities (IOUs), municipal/government owned Public Power Utilities (PPUs),
Independent Generators, and the Telecommunications Companies, who universally maintain good operating procedures, and who’s personnel
are exceedingly good at the work they perform.

This marvelous complex machine we call the national power grid is the net result of generations of successful modernization efforts. Recall that
we once had:

Small, local power generation plants, located within towns and cities, owned and operated by the local utility, and equipped with dedicated in-
house provided, custom-leased, or owned telecom circuits, in which personnel relied on voice and/or written (paper and pencil) communication
and control procedures for local balancing or load sharing.

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This original model evolved into large IOU and PPU operated generation, transmission, and distribution, controlled via utility-owned and
operated telecom voice and SCADA systems, with balancing control centers at the at utility’s dispatch center.

Finally, today's environment, where different entities handle generation, transmission, and balancing activities, where often ISO-based BAs and
RCs cover ever larger areas that the IOUs once covered, and where much of the telecom glue that ties voice and SCADA together is now being
provided by Telecom Common Carriers using high-speed IP-based transport instead of proprietary and individually-owned, private
circuits. Routing of these common carrier transports is now beyond the direct control of the utility operator providing and using these signals. In
addition, routing may now traverse many hundreds of miles beyond the local utility’s area of operation.

In light of the grid evolution described, the control points for grid balancing as well as general transmission control have shifted steadily away
from the local utility level to increasingly centralized centers of control — geographically removed from local transmission assets, generation and
load. This shift applies both to the flow of people-to-people communication as well as how the SCADA is wired. Currently, generation and
transmission operations are singularly focused on the wider area BAs providing the balancing function, and RCs for transmission operations. If
the grid were to seriously sever itself into islands – or worse yet completely black out — the plan would be to execute one of the NERC approved
strategies designed to be implemented from centralized control points assuming existing telecom and computer /SCADA resources remained on-
line. Failing that, the protocol would shift to attempting to start and balance small local pods of generation and load, followed by synchronizing
the small pieces back into the larger grid.

Obviously, this later process is inherently messy since utilities have in many cases markedly reduced the scale and responsibility of local control
centers in terms of support communications for SCADA as well as basic power control. IOU’s could quickly identify local control points, but
would then realize the balancing SCADA is no longer provisioned to support a local balancing function, forcing both the utility and their 3rd
party generation partners to communicate manually.

The first pinch-point in this regard would be a potentially jammed or inoperative public telephone system and/or congested cell phone network –
both wholly inadequate for coordination with multiple independent generators. Given how fragile a small system is during early restoration
stages with the possibility of grid IP-based messaging networks unreliable, people-to-people coordination still needs to be locally-based one-to-
many, like soldier radio comms, or a conference call, as dynamic circumstances frequently demand that action be taken in several places at once

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