Electromagnetic pulses (EMPs) are a little understood phenomenon that many believe could pose a serious threat to our
nation’s critical infrastructure. EMPs may sound like something out of a science fiction novel: a nuclear blast at high altitude or
particles from a solar storm interacting with the Earth’s magnetic field to cause disruption or damage to the electrical grid and
electronics. This paper will outline the EMP threat, and provide an overview of current and potential mitigations, including the
state of legislative and policy activity. It draws on the 2008 report from the Commission to Assess the Threat to the United
States from Electromagnetic Pulse Attack, reputable open-source resources, and interviews with subject matter experts in
government and private industry.
The US1 and Soviet2 militaries learned first-hand of the potential
consequences of a major EMP event when conducting high altitude nuclear
tests over 50 years ago. In 1962 for example, a U.S. military exercise dubbed
“Operation Starfish” exploded a 1.4 megaton nuclear warhead 240 miles
above Johnson Island in the Pacific Ocean. Alarmingly, the resulting EMP field
caused street lights to blow out and affected telephone and radio
communications in Hawaii, 900 miles away.3 Fearing its use as a “first strike”
weapon that would take out critical military command and control
infrastructure, both superpowers spent the following decades hardening their
military apparatuses against such an attack. Our civilian infrastructure,
however, has remained largely unshielded from severe electromagnetic
events. Much of the knowledge on the effects of EMPs has been classified
due to its national security implications.
Over time, knowledge of the threat from an EMP has made its way into the
public consciousness. The Commission to Assess the Threat to the United
States from Electromagnetic Pulse Attack (the Commission)4, a
congressionally-established body, produced two notable non-classified
reports (along with several classified reports) which included an Executive
Report in 2004 and a more detailed 2008 version. The 2008 report went
into greater depth regarding the risks posed to individual critical
infrastructure sectors, including recommendations for risk mitigation. These
reports and other subsequent studies also outline the related threat of severe
solar storms, whose effects are similar to the effects of nuclear EMP attacks.
Eight years later, however, few of the Commission’s recommendations have
been addressed on any meaningful scale in the United States.

Figure 1: 2008 Commission Report

In March 2016 the United States Government Accountability Office released a report on critical infrastructure protection relating
to the threat posed by electromagnetic risks. The paper further supports our findings that, while progress is being made to
assess vulnerabilities and improve grid security, the United States is unprepared for the effects of an EMP and more work is
necessary to protect the American public.


http://www. eiscouncil.org/English/Resources/ResouceInside.asp?itemId=10427


W hat are the primary current and potential emitters of electrom agnetic pulses?
In order to fully understand the threat surrounding EMP, it is important to know some basics about the science of EMP and EMPlike events. An EMP is a burst of electromagnetic energy. The changing electrical and magnetic fields may interact with electrical
and electronic devices to produce damaging voltages and currents. EMPs vary widely in magnitude and range, and are caused
by a variety of sources including lightning, electrostatic discharge, power line surges, and other sources. The largest known
sources of EMP are nuclear explosions, and the geomagnetic disturbance (GMD) caused by a solar flare or Coronal Mass
Ejection (CME).
Although all nuclear detonations cause some EMP effects, a nuclear weapon could be employed in a way intended specifically
to maximize the EMP effects. A high altitude electromagnetic pulse (HEMP) is caused by a nuclear device exploding at high
altitudes above Earth’s surface (generally recognized to be anywhere between around 30km to 400km). The nuclear EMP is
comprised of three major components. The first EMP component (E1) is an extremely fast “electromagnetic shock” that
happens just nanoseconds after the nuclear explosion. The second EMP component (E2) has many similarities to the
electromagnetic pulses produced by lightning strikes. The third EMP component (E3) is a much slower pulse, lasting tens to
hundreds of seconds following the blast. The E3 pulse has a very similar profile to severe geomagnetic disturbances (GMDs),
which can be caused by large solar CMEs. Figure 2 provides an overview of these various threats5:

Figure 2: Nuclear and Solar Environments of Concern
The E1 pulse is produced as gamma rays from the explosion interact with Earth’s atmosphere to produce radio frequency waves
in the electrical and magnetic fields. These waves impact everything within a line-of-site of the explosion’s center point. This
area can be quite large (even encompassing an entire country or continent) depending on the position, altitude, and strength of
the explosion. As these waves travel through electronic systems, they induce voltage and current spikes. This can cause
interference, damage, or in severe cases destruction of the electronic systems, and could affect anything from consumer
electronics to the control systems in power plants and other critical infrastructure. There has been some testing of the actual
impact of an E1-type pulse on various electronics, but it is not comprehensive by any means.
The E2 pulse does not pose a significant threat by itself, because of its similarity to the effects of a lightning strike. Although
direct lightning strikes can be quite damaging to electronics, most susceptible technology, particularly in critical infrastructure,
is relatively well-hardened against their electromagnetic effects. There is a possibility that the E1 pulse could disable the
components that protect from lightning-related electromagnetic effects, exposing systems up to the possibility of damage from
the E2 pulse. This demonstrates the complexity of accurately modeling or testing the full range of effects from an EMP.
Both the E3 pulse from a HEMP, and the GMD from a solar flare can cause damage only to components attached to very long
conductors (several miles or more). This puts at risk long-line electricity systems, long-line telecommunications infrastructure,
and some long fiber-optic lines, such as transoceanic cables6. Because E3 and GMDs can only couple to extremely long cables,
however, components such as household appliances and electronics are not generally thought to be at risk.
“Based on DoD and Congressional EMP Commission’s EMP test databases we know that smaller, selfcontained systems that are not connected to long-lines tend not to be affected by EMP fields. Examples of
such systems include vehicles, hand-held radios, and disconnected portable generators. If there is an effect
on these systems, it is more often temporary upset rather than component burnout. On the other hand, threatlevel EMP testing also reveals that systems connected to long lines are highly vulnerable to component
damage, necessitating repair or replacement. Because the strength of EMP fields is measured in volts per




meter… the longer the line, the more EMP energy will be coupled into the system and the higher the probability
of EMP damage.”7 - Dr. George Baker, member of the Commission

W hich emitters pose the highest risk to the public?
Each of the various EMP threats have unique properties that contribute to their inherent risk. At a very high level, the risk to the
United States posed by a specific EMP threat may be represented by plotting such events on a diagram of “likelihood” of
occurrence versus “potential destructive power.” Potential destructive power considers the sum total of impacts both by the
initial event and from the cascading impacts an event might trigger. This includes damage to property, lost economic output,
and loss of human life. For instance, a HEMP blast’s destructive power would include both the assets directly affected by its E1
and E3 components and the ripple effects it might have through electric blackouts, including potentially compromising other
critical infrastructure.
Figure 3 depicts this dynamic:

Figure 3: Risk Matrix for EMP Events
Figure 3 shows EMP threat scenarios together with non-EMP threats for context. In general, common events like lightning or low
intensity solar events, and less common but more severe events like a hurricane, serve as the design basis for protective
features in critical infrastructure. As such, their threat has been mitigated through active or passive design features. Very
destructive, but more unlikely events (such as a nuclear conflict) may not be mitigated, as the threat is considered too difficult
to counter (at least through design of a critical infrastructure component).
Some experts argue that the US faces an existential threat from EMP (whether HEMP or GMD):
“Natural EMP from a geomagnetic super-storm, like the 1859 Carrington Event or 1921 Railroad Storm, or
nuclear EMP attack from terrorists or rogue states, as apparently practiced by North Korea during the nuclear
crisis of 2013, are both existential threats that could kill up to 9 of 10 Americans through starvation, disease,




and societal collapse. A natural EMP catastrophe or nuclear EMP attack could blackout the national electric
grid for months or years and collapse all the other critical infrastructures--communications, transportation,
banking and finance, food and water--necessary to sustain modern society and the lives of 310 million
Americans.” Dr. Peter Vincent Pry, Commission member, in his 2015 testimony to a joint House committee8
There is, however, some debate about the likelihood and potential destruction of a HEMP or solar GMD. While it’s known that
some rogue states are actively seeking or have acquired nuclear weapons, the ability to miniaturize such a weapon to allow it to
be placed on a launch vehicle capable of reaching HEMP altitudes above the US would represent another step in technology.
Furthermore, it is debatable whether any threat actor (state or non-state) would choose to use a single nuclear weapon in a
HEMP attack rather than in a traditional air- or ground-burst detonation in a major population center. Solar activity on the level
of the Carrington event is known to occur with some frequency, but the charged particles ejected must be directed at the Earth
to cause a GMD. This seems to occur infrequently.
The consequences of an EMP event are also not fully understood. Models show a significant threat to critical infrastructure, but
in the absence of more extensive real world testing some uncertainty remains. Even in a worst-case scenario in which a large
fraction of the high-voltage transformers connected to long electrical lines and critical infrastructure control systems are
destroyed, the recovery may not take the months or years that some have asserted. While it’s true that at the current rate of
production, replacement of these assets would take months or perhaps years, it also stands to reason that the world’s industrial
capacity (and the profit motive in the global market economy) would react by shifting resources to speed up the recovery.

The Black Swans
Several other nations may have the ability to launch a nuclear HEMP device that could seriously degrade our critical
infrastructure. Figure 4 provides an overview of the global nuclear weapons situation based on data from the Federation of
American Scientists, CIA World
Factbook, Nuclear Threat
Initiative, and U.S. Census
Bureau.9 Some countries, such
as France, Israel, and the
United Kingdom, are our
staunch allies. India and
Pakistan, while sworn enemies
to each other, are both current
military allies of ours.
Meanwhile China, while an
economic competitor, would
appear to have little incentive
to initiate an EMP attack on the
United States given our
massive retaliatory capability.
In other words, they have too
much to lose. Much of the
threat is therefore narrowed
down to what experts call
Figure 4: Worldwide Nuclear Snapshot
“rogue states.” These rogue
states, however, are not
believed to currently have the technology to construct a sufficiently miniaturized nuclear weapon, to allow delivery it to the
necessary altitude above the United States.
Another scenario that has been considered is the use of a HEMP by a terrorist or criminal organization. Nuclear materials falling
into the hands of terrorists has been a focal point of our counter-terrorism apparatus for decades, and became especially
worrisome following the events of 9/11. A HEMP attack would require that the organization know how to operate and detonate
the nuclear device as well as possess the equipment to deliver it at least 30km into the air. In his 2015 Congressional
testimony, Dr. Pry suggests there are multiple scenarios under which a terrorist organization could accomplish this. Short or




intermediate range missiles, such as the SCUDs that are popular across the Middle East, could be loaded onto a ship and fired
from off the U.S. coastline. However, the technology needed to miniaturize a nuclear device, mount it on a missile, and fire it
accurately enough to cause a widespread EMP catastrophe is scarce. Dr. Pry also mentions that aircraft which can reach Mach
1 may be able to do a zoom climb to 30km and detonate a nuclear device, though terrorists’ ability to possess and fly jets as
well as their capability to access U.S. airspace is dubious. Another scenario involves the use of high-altitude weather balloons to
carry a nuclear device high up into the atmosphere, a style that was actually the preferred method of high altitude nuclear
testing by the U.S. during the 1950s and early 1960s. Even with this relatively low-tech delivery method, terrorist would have to
acquire a nuclear weapon. Beyond our strong national security efforts to stop the spread of such weapons, nuclear-capable
countries – even rogue ones – would be unlikely to give away such valuable geopolitical commodities to terrorist groups. Finally,
in the rare event that a terrorist group does acquire a nuclear weapon, it is questionable they would attempt to use it as an EMP
as opposed to a low altitude or ground-level detonation that would be much more dramatic and cause much more immediate
destruction. Would they be willing to gamble that they could actually pull off a HEMP attack that could shut down the entire
electric grid and cause mass chaos as opposed to the more certain impact of a detonation in a major population center?

Figure 5: Area Effected by EMP by Height of Burst

To be certain, there are numerous impediments
standing in the way of even a determined terrorist
or rogue state leader who might want to use a
HEMP against the U.S., causing us to classify
them as black swan events. However, there are
variables that make this threat very serious. For
one, while lower altitude blasts affect smaller
geographic areas with EMP, they also enhance the
strength of the E1 pulse in the effected region.10
Secondarily, the way our power grid is partitioned
makes it entirely possible that even a crude
nuclear weapon detonated at the lowest EMPproducing limits (30km) would cover a multi-state
area. If placed strategically over the Eastern North
American Electric Reliability Corporation (NERC)
Interconnection, this could cause a blackout for
roughly 75% of the country and the most
populated portions of Canada provided the EMP
enough key transformers and other grid assets.

Another method by which terrorists could employ EMP against the nation would entail a coordinated non-nuclear EMP attack
against key critical infrastructure segments. Non-nuclear EMP devices, such as radio-frequency weapons (RFW), can impact
critical infrastructure much in the same way as the E1 component of a nuclear HEMP11. The difference is that the affected
region is much smaller, typically very local. Therefore, any group attempting to inflict a systemic failure of the electric grid or
other critical infrastructure would need to coordinate an attack at multiple facilities in close time proximity. While complicated,
this may be technically feasible should organizations be able to replicate the U.S. Federal Energy Regulatory Commission
study12 which identified that the entire U.S. electric grid could be blacked out for weeks or months by knocking out only nine of
the country’s 55,000 electric transmission substations. It is then feasible, if unlikely, that a large-scale coordinated non-nuclear
EMP attack on the electric grid and other critical infrastructure could result in a severe national event.

The Carrington-class Solar Superstorm
Solar storms differ from nuclear EMP in that they do not affect short line electronic systems. Only assets that are attached to
very long wires or cables, like large electricity transformers, experience EMP from GMD. Transformers are typically well protected
from moderate surge events such as lightning and normal solar weather. They are not, however, designed to protect against
massive GMDs that occur very infrequently. The most famous of these events occurred in 1859 and was dubbed the Solar
Storm of 1859 or Carrington Event13 due to the detailed observations of the solar phenomenon by British astronomer Richard
Carrington. During this event, energy from a coronal mass ejection on the surface of the Sun caused a GMD on Earth that
coupled with telegraph wires (the only systems of the time long enough to experience solar-induced surge) causing forest fires




from exposed lines, lighting telegraph paper on fire, and destroying the newly-laid intercontinental telegraph line that ran under
the Atlantic Ocean and connected our continent with Europe14. Fortunately, 1859 society did not depend on electrical systems
the way we do today.
In 2010, Lloyds of London published a groundbreaking report15 in conjunction with Atmospheric and Environmental Research
(AER) that indicated a Carrington Event-level GMD had the potential to cause extended blackouts for 20-40 million Americans at
a total economic cost of $600 billion to $2.6 trillion. The report also acknowledged that the estimates may be understated.
Additionally, the report listed the projected recurrence of such an event at 150 years. By that count, we are seven years overdue.
As AER/Lloyd’s put it in a later 2013 report16: “The hazard posed by geomagnetic storms is one of the most concerning due to
the potential for long-term, widespread power outage. While the probability of an extreme storm occurring is relatively low at
any given time, one will occur eventually. And as the electric infrastructure ages and we become more and more dependent on
electricity, the risk of a catastrophic outage increases with each peak of the solar cycle”
Unlike the black swan events discussed earlier, a Carrington-class solar superstorm is almost certain to occur at some point.
Though it may not have the same drama as a nuclear attack, the impact on our critical infrastructure, especially the power grid,
could be widespread. As such, we have classified this threat as having the potential to result in a national level disaster, similar
to an advanced cyber-attack or an extreme hurricane (e.g. Katrina). To give some context, Hurricane Katrina is estimated to
have caused $125 billion in total economic losses, with $35 billion of that figure insured losses.17 These numbers are far
outstretched by even Lloyd’s of London’s lower bound damage estimates for a Carrington-class solar storm.

Other EMP Threats
Though many other potential EMP threats exist, such
as lightning strikes, moderate solar storms, and
isolated non-nuclear EMP attacks, their impacts would
be more local in nature and would not constitute a
national level threat or recovery effort. Understandably,
private sector owners and operators of critical
infrastructure are better prepared for these threats.
These events occur with relative frequency, not just in
models and simulations. For instance, solar storms
tend to occur hundreds of times in every 11-year solar
cycle.18 Most of these are not powerful enough to
cause much real damage to critical infrastructure, but
even relatively powerful storms like the 1989 storm
that knocked out the Quebec power grid can be
recovered from in days or weeks, after which life goes
back to normal. Even an isolated terrorist attack using
a non-nuclear EMP weapon, while potentially crippling
to one facility, would be relatively limited in scope,
Figure 6: Interconnectivity of Critical
unable to bring about a systemic collapse of the power
grid or other critical infrastructure. Quite frankly, terrorists would be far more likely to use conventional methods for such an
attack as they would tend to be as effective in disabling the assets, far less complex to plan, and more cost effective.

W hat critical infrastructure sectors are most vulnerable to electrom agnetic pulses?
In an EMP event, there are myriad potential consequences for critical infrastructure. The threat to the public from various EMP
events is driven both by the potential degradation of individual critical infrastructure assets and sectors and from the
interconnectivity of the multi-sector systems that sprawl across the country. In other words, the fact that an EMP can knock out
the power grid means it has the potential to cause great inconvenience or even in some cases death (imagine losing electrical
heating in the middle of winter in the upper Midwest). An added layer of complexity comes in when a hospital loses power


‘Solar Storm Risk to the North American Electric Grid,’ Atmospheric and Environmental Research (AER), May 2013


though. Now not only is the damage manifested just in the lack of electricity, but in the lack of a vital emergency service. Backup
generators may keep operations going for a time, but unfortunately the fuel and energy infrastructure, such as oil and natural
gas pipelines, can be affected by EMP as well, both directly and through disruptions in the electric grid. Figure 6 illustrates the
interconnectivity of various critical infrastructure across the nation:
Despite the complexity of the relationships between our critical infrastructure assets, it is clear from the Commission Report as
well as other experts’ opinions that our Electric Power Infrastructure represents a center of mass of the threat from EMP. This
stems largely from our dependence on electricity and electronic control systems that enable or control our other critical
infrastructure assets. George H. Baker, who served on the Committee explained:
“Among the critical infrastructure sectors, EMP risk is highest for electric power grid and telecommunication
grids… These infrastructures are the most vulnerable due to their organic long lines. And they are also the
most critical to the operation and recovery of the other critical infrastructure sectors… If we have to pick one
infrastructure to protect, the top choice would be the electric power grid.”19

Vulnerabilities of Electric Power Infrastructure
The electric grid can be divided into three distinct constituents: generation, transmission, and distribution. Generation is
comprised of all the various coal, gas, nuclear, hydroelectric, etc. power plants that create electric energy for our consumption.
Our generation systems are at most risk from the E1 component of a nuclear HEMP since solar EMP caused by GMDs and the
E3 component of HEMP can only couple with extra-long cables (so the voltage and current spikes would be absorbed in the highvoltage transformers that connect to the transmission lines). Power plants are operated by digital electronics such as digital
supervisory control and data acquisition (SCADA) systems. The E1 pulse can disrupt or damage SCADA and other systems,
possibly causing the plant to be inoperable. Even in the event of a safe shutdown, the replacement of damaged electronics
necessary to ensure a successful and safe restart could be time consuming. Importantly, due to the interconnected nature of
the electric grid and the complexity of safely balancing load during reconstitution, severe impact can be caused through a
relatively modest number of key generation plants being disrupted.
Transmission is made up of the assets that carry the electricity from a plant, often over long distances, to the population centers
where it will be consumed. Transmission of electric power starts near the plant with a step-up transformer that converts
electricity to higher voltages. This high voltage electricity is then sent over high voltage lines to substations with a step-down
transformer nearer to a population center that convert the electricity back down to lower voltages. Our transmission system is
particularly susceptible to EMP damage for a number of reasons. First, the electronics that help the transmission system
function are more vulnerable to E1 than their counterparts in the generation system because they are usually out in the open,
not enclosed within buildings (which can serve to dampen the E1 pulse). Second, the high voltage transformers of the
transmission system are connected to long cables which serve as antennae for the E3 component of HEMP and for GMDs.
Historically, transformers have been damaged by geomagnetic currents caused by solar storms. An E3 from a HEMP would likely
be more powerful than a solar GMD. Third, recovery from transmission failures can be complicated because of the relative
remoteness of the assets and their scarcity. Substations are often unmanned and geographically disbursed, making even minor
repairs more time-consuming, especially if communications assets like telephone lines and cellular networks are also impacted.
Furthermore, large transformers typically require long lead times to procure. Replacement of a large number of these assets
would be costly and time consuming, and may require expanded production by the limited number of global manufacturers.
The distribution system is composed of the small transformers and shorter wires that bring electricity to our houses, businesses,
and other consumption points. Like the generation component, distribution is only likely to be impacted by E1, and thus would
likely not be affected by a solar event (other than by the loss of electrical supply from the transmission system).
In summary, the electric grid is vulnerable across its components to multiple types of EMP event. While the system writ large is
more at risk from a nuclear HEMP because of the E1 component that can affect a wide array of electronic equipment, large
solar storms also pose danger to the transmission systems that are the lynchpin between generation and load. Unfortunately,
large-scale load losses of over 10% are expected with a nuclear HEMP event, which would make system failure very likely.
Powerful solar storms on the scale of the 1989 event that knocked out the Quebec power grid20, are considerably less powerful
than a “typical” nuclear EMP because of the lack of E1; however, a “100-year superstorm” on par with the Carrington Event of
1859 would almost certainly cause widespread systemic blackouts. While the electric grid is supposed to function with
safeguards that allow “islanding” of compromised sections, the geographic scope and simultaneous impact of a HEMP attack or
large solar storm would likely render islanding moot.




Vulnerabilities of other Critical Infrastructure Sectors
While risk to the electric grid is the largest concern for an EMP event, the impacts to key industries are key to understanding the
full scope of the EMP threat. While some sectors, such as telecommunications, may be directly impacted by the EMP, the
primary factor driving degradation would typically be the long-term loss of electricity. The below discussion highlights some of
the most severe vulnerabilities of other critical infrastructure to EMP:

Telecommunications – The telecommunications grid – the mix of equipment necessary to send and receive voice,
data, video, and other messaging, including internet and phone networks – is almost entirely dependent on sustained
electricity production. Backup generators may provide emergency service for days, but cannot accommodate prolonged
outages unless generator fuel supplies are secured. Communications are also considered vital to the recovery of other
critical infrastructures, and any prolonged outages may have detrimental impacts to long-term recovery efforts.
Additionally, long telecommunications lines and some fiber-optic cables (with repeaters) are vulnerable to E3 and solar
events, and telecom SCADAs would be vulnerable to the E1 component of a nuclear HEMP.

Banking and Finance – Our banking and financial services system is extremely reliant on digital elements that require
electricity and telecommunications infrastructure to be working. Even though our banking system has some of the most
robust protections and recovery mechanisms for cyber and physical threats, these mechanisms are not designed to
sustain operations during prolonged blackouts unless a source of fuel is available to backup generators. In the event of
prolonged electricity shortage, significant effort would be required to operate stock exchanges, banks, and ensure citizens
access to their financial resources.

Fuel/Energy Infrastructure – Fuel is the pre-cursor to many of our other infrastructure sectors, including the
electricity sector. Oil and natural gas account for over 60% of our domestic fuel consumption, and these resources are
distributed across the country along long pipelines. These pipelines are monitored and controlled by electronic systems
similar to those which control the electric grid, and are thus vulnerable to E1 from a nuclear HEMP. Beyond the direct
EMP vulnerability, like other sectors the fuel and energy assets would be unable to function fully during prolonged
electricity blackouts. Slowdown in fuel production and refinement would lead to longer, more difficult recovery of electric
power and other critical infrastructures.

Transportation Infrastructure – While some might picture the impact of an EMP event on transportation mass
traffic jams caused by incapacitated cars, the real vulnerability is slightly less dramatic. Various transportation modes
would be impacted by EMP in different ways. The immediate effect on roads and the railway system would be the failure
of signals due to electrical outage. Until backup power was available, there would be significant disruption of fuel supplies.
Even if airports and seaports maintained sources of backup power, a prolonged, large scale blackout cloud cause
significant delays in the delivery of fuel which would hamper air travel and maritime cargo industries.

Food Infrastructure – Our food infrastructure is extremely dependent on other infrastructures, especially electricity,
fuel and transportation. In the event of a severe EMP event, production could be impacted by the inoperability of
industrial farming equipment due to reductions in fuel availability. Likewise, fuel shortages could cause shipping delays,
while long-term blackouts would almost certainly cause issues for food processors and large regional food storage

Water Supply Infrastructure – The continued survival and health of our population relies on the availability of clean
and accessible drinking water. EMP can cause disruptions to the water supply through malfunctioning SCADA and longterm lack of electricity. Long-term blackouts can also disrupt wastewater removal systems and industrial water delivery to
other critical sectors, such as farming.

Emergency Services – Emergency services are critical to the preservation of law and order, as well as health and
safety. On the local, state, and Federal level, millions of firefighters, police officers, doctors, and various other public
servants provide these critical services. Prolonged electricity blackouts or loss of telecommunications capabilities can
cause disruption to these services in the short term. Ironically, a crisis situation such as a severe EMP event would almost
definitely generate higher than normal demand for emergency services, as was observed after severe events such as
9/11 and Hurricane Katrina.


Space Systems – Space systems, specifically satellites, have become an increasingly large component of modern
society even since the Commission Report in 2008. Today, people often check traffic or navigate even short car trips from
their smartphone GPS systems. Beyond this, satellites in Low Earth Orbit (LEO), provide an increasing array of other
functions, from communications, to weather tracking, to national defense. Satellites in LEO are particularly vulnerable to
HEMP and solar events and are particularly difficult or costly to harden.

W hat are the main mitigation activities that are available to protect against EM P?
Given the numerous potential EMP impacts due to the complexity of our critical infrastructure systems, developing a holistic
mitigation strategy is difficult and potentially costly. A focused, prioritized approach – perhaps one that begins with the electric
grid – could yield great benefits to our country. One key point is that the answer is not a purely engineering or technology
solution. As the Commission states, “the appropriate national-level approach should balance prevention, protection, and
recovery.” To this end, the responsibility of protecting our critical infrastructure from EMPs is shared by both government and
private sector owners and operators. Figure 7 outlines the shared responsibility for EMP mitigation:

Figure 7: Shared Responsibility of EMP Mitigation

The Shared Responsibility Model
Much of the government’s responsibility for mitigating EMP comes in the form of national defense policy and operations. This is
not surprising considering that intelligence, interdiction, and deterrence in support of EMP protection is not dissimilar to the
same core activities in support of general protection against weapons of mass destruction (WMD). A nuclear bomb detonated at
1km above a U.S. city is as much, or more of a concern as a nuclear bomb detonated at 100km above the country, however
different the results might be. According to the Commission, in order to protect against EMP attacks, “the development, trading,
and movement of critical materials” must be identified early, and the U.S. must hold perpetrators “at risk of capture or
destruction, whenever and wherever in the world they operate.”
In addition to defense activities, the government is likely the organization most able to take the lead on developing and
improving early warning systems for coronal mass ejections which can cause severe solar weather on Earth. With current
technology, the National Oceanic and Atmospheric Administration (NOAA) can provide 12-hour notice of an impending solar
event to the proper agencies and industries. To determine storm intensity, NOAA has a satellite called the Advanced
Composition Explorer (ACE) which is stationed about 932,000 miles from Earth, directly between our planet and the Sun (at a
location called the L1 point, which keeps it directly between the Earth and Sun at all times). This satellite can detect the
magnitude of a solar storm and provides 15 to 60 minutes of warning to the Earth. ACE is now 17 years old and will soon be
replaced by the Deep Space Climate Observatory (DSCOVR) satellite. More research is needed to develop an early warning
system that can predict solar events well in advance.

Finally, and perhaps most importantly, the government could develop effective regulation to promote EMP protection and
preparedness. This includes ensuring that key infrastructure assets are identified and hardened to the extent practical by
private sector owners and operators. Without such regulation, it may be challenging for an individual owner (such as an electric
utility) to justify the expense of hardening to its customers or shareholders. Private industry must, in turn, comply with regulation
and implement best practices to mitigate the risk from EMP.

Technology Implications of Mitigation
The primary mechanisms necessary to protect most electronic and electrical assets in critical infrastructure systems, and
particularly in our electric grid, are tried and true technologies that are already in use in different applications.
A Faraday cage is essentially an enclosed container made out of metal or other conductive material that serves to shield its
contents from outside electromagnetic pulse or current. Although highly engineered Faraday cages exist and offer much better
protection qualities, anything from a building to a car to a metal cabinet can serve as a makeshift Faraday cage. In order to
ensure critical infrastructure is protected from EMP, systems necessary for safe operations would need to be placed in Faraday
cages (which could be physically built around individual components, computer rooms, or entire building). These cages would
need to be designed specifically to resist the E1 pulse from a HEMP nuclear detonation (in addition to the slower pulses
associated with lightning and other non-nuclear sources). These types of systems would not be affected by solar storms or the
E3 pulse from a HEMP event since they are typically not connected to long cables.
Surge protectors designed specifically to interrupt the very high currents that can result from a solar-induced GMD, or the E3
pulse from a nuclear HEMP, would need to be installed in all systems connected to very long conductive lines. Most importantly,
these should be installed on the costly and difficult-to-replace high voltage transformers that connect to our electrical
transmission system. This type of technology represents an engineered mitigation to harden against both HEMP and solar GMD
events, and requires no prior warning since the protective device would be in place at all times.

Complexity of Mitigation
An important characteristic of EMP mitigation is acknowledgement of the complexity of our critical infrastructure. To give some
context, the U.S. electric transmission system, which is only one of three components that make up the entire electric grid, is
comprised of approximately 200,000 miles of power lines21. In addition, mitigation efforts and responsibilities cross sometimes
blurred lines among different federal, state, and local governments as well as private sector stakeholders.
One expert interviewed for this paper, who worked on EMP testing in the military and subsequently spent years in the electric
utilities industry described the complexity:
“If you harden 100% against HEMP, you are fully protected from Solar EMP, but not the other way around.
Hardening 100% against HEMP is unrealistic though because it’s too complex and costly. You would need to
follow a model similar to what the military has done, i.e. prioritizing key systems and hardening only the most
critical ones. That way you can re-constitute after a disaster.”
With this level of complexity, the Commission ultimately concluded that protecting the entire power grid system, or even all its
high value components, was impractical and instead recommended preparing for the widest possible scenarios of GMD and
EMP with a focus on quick response and repairs. The Commission also recommended conducting further research into costeffective mitigation and preparation. The Electric Power Research Institute (EPRI) issued recommendations in 201322 that

Inter-agency cooperation
More robust modeling capabilities
Focused hardening
Availability of shared backup and replacement components

While some of these recommendations have gained varying degrees of traction, mitigation activities have not yet been
implemented. Tellingly, five years after the Commission’s 2008 report was published, EPRI’s report ends with a call for more
research into EMP scenarios.

Cost of Mitigation




Determining the cost for realistic EMP mitigation scenarios is difficult due to the complexity discussed above. Since the electric
sector is decidedly the most important component to overall resiliency, the most comprehensive cost estimates focus on
ensuring the electric grid is protected from EMPs. The Commission provided cost estimates for some of the larger or more
system-specific initiatives, such as hardening major transformers. In total, the Commission’s initiatives would cost between $3.3
billion and $4.5 billion in 2015 dollars. A more recent and robust cost estimate for protecting the U.S. electric grid was
developed by The Foundation for Resilient Societies, a non-profit focused on infrastructure protection, at the request of the U.S.
House Oversight and Government Reform Committee. Their model, which is updated periodically and presented in a detailed
Excel format available online23, takes a systems approach that includes initiatives necessary to protect key supporting
infrastructures in telecommunications, natural gas pipelines, and rail transport (for coal shipping to power plants) from both
nuclear EMP and severe GMDs. Their estimate to protect most of the transmission and distribution systems as well as half of
the U.S. generation capacity ranges from $10 billion to $30 billion, or between $1.12 and $3.38 per month for every electric
customer over a five year period.
While those figures are substantial sums of money, some context is necessary to fully understand the scale. For one, the 2015
Federal budget was $3.8 trillion. U.S. foreign military aid – which can be construed as a method of promoting national security –
was roughly $28 billion for 2009-2013, 75% of which went to just two countries: Israel and Egypt24. Alternatively, a program of
the U.S. Department of Energy (DOE) for smart grid modernization may serve as a benchmark. Over a five year period from
2010-2015, the program provided Federal funding of roughly $5.2 billion with matching funds from electric utilities of about $7
billion dollars. According to the Foundation for Resilient Societies, “a low-cost EMP & GMD Protection Program, if providing 50%
Federal grant eligibility, would cost taxpayers about as much as the Smart Grid Program while protecting the U.S. electric grid
from both severe solar storms and man-made EMP attack.”

W hat Is the Current State of Mitigation for EMP?
There have been efforts to pass legislation designed to require better preparedness and mitigation for both GMD and HEMP
events. Congressman Trent Franks from Arizona introduced the Secure High-voltage Infrastructure for Electricity from Lethal
Damage (SHIELD) Act to the House in 2013. The SHIELD Act remained stalled at the time of this paper’s writing. The SHIELD Act
would require that utilities install grid-saving equipment and surge protectors at roughly 300 critical transformers. Another piece
of legislation, the Critical Infrastructure Protection Act (CIPA), is also sponsored by Congressman Franks. It would direct DHS
to (1) include the threat of EMP events in national planning frameworks; and (2) conduct outreach to educate owners and
operators of critical infrastructure, emergency planners, and emergency response providers of the threat of EMP events.25 This
bill passed in the House in November 2015 and currently sits with the Senate Committee on Homeland Security and
Governmental Affairs.
A GAO report noted some isolated efforts to improve EMP resiliency. These efforts include producing several reports that deal
with EMP, identifying mitigation efforts, strategy development and planning, and conducting training exercises. From a
regulatory perspective, NERC touts its GMD standards that were approved by the Federal Energy Regulatory Commission (FERC)
in 2014 as proof that it is taking prudent steps toward EMP protection.26 These standards have been criticized by EMP
protection advocates, however, for ignoring nuclear EMP and lacking teeth for GMD threats due to unrealistic risk modeling.27
On October 29, 2015, the White House’s National Science and Technology Council released its strategic plan to prepare for an
extreme space weather event. It requires national departments, agencies, and service branches to reach a number of
benchmarks within the next two years. These benchmarks are centered on creating engineering standards, vulnerability
assessments, decision points, thresholds for action, developing mitigation processes, and improving response and recovery
In response to a FOIA request we filed with Bonneville Power Administration (BPA), we have learned that BPA has recognized the
potential danger from natural GMD/EMP events and has committed $251,000 of a total budget of $503,000 to a study of the
risks they present to the BPA system, particularly the electric grid. This study runs from October 1, 2015 through September 30,
2017 and is designated TIP 359: Improved System Modeling for GMD and EMP Assessments. In the words of the statement of
purpose for this study: The overall objective of this work is to contribute to geomagnetic disturbance (GMD) and
electromagnetic pulse (EMP) assessments for the BPA system, with various-level models of improved accuracy. This ultimate
benefit includes enhanced decision-making regarding planning, operations and mitigation strategies in the presence of GMDs.




This will be achieved by validating several GMD-related system parameters and modeling approaches for the BPA system,
thanks to available data measurement during GMD storms.
Although the U.S. approach to EMP is the focus of this paper, it should be noted that the EMP threat is not isolated to our nation.
Industrialized, electricity-dependent modern economies all over the world exhibit varying degrees of vulnerability to EMP. Some,
like South Korea, Japan, and Israel – due to their proximity to and rivalry with rogue states North Korea and Iran – and Northern
European nations – due to their exposure to solar weather – would appear to be at greater risk than the U.S. The Electric
Infrastructure Security (EIS) Council put out a report28 in 2013 that identified Scandinavian countries and the UK as some of the
most advanced in EMP mitigation, largely due to their longstanding experience protecting against solar weather. South Korea,
Japan, and Israel appear to have conducted general studies into the effects of EMP, although many details on past, current, and
future steps to protect against EMP were not made available for the report. The European Space Agency (ESA) announced in
November 2015 that it was working with 14 European nations to develop a warning network for extreme space weather events.
It’s clear that nations around the globe are beginning to take EMP more seriously.
Back in the U.S., in the absence of national-level EMP protection efforts, many states have taken the matter into their own
hands. According to Michael Caruso in his House testimony in May of 2015, 18 states have taken proactive efforts to protect
their grids from EMP: Alaska, Arizona, Florida, Kentucky, Maine, New Hampshire, New York, North Carolina, Colorado, Indiana,
Louisiana, New Mexico Oklahoma, South Carolina, Texas, Utah, Virginia and Washington.29 This trend may continue and even
expand if the Federal government does not offer a more comprehensive strategy for EMP protection.
Why does the United States remain relatively unprepared for EMP threats? Below, we highlight some of the common themes
that appear to be hindering more comprehensive mitigation against EMP, particularly in the electricity sector.

Continued Misunderstanding of the EMP Threat
One key issue appears to be general misunderstanding of EMP and the threat it poses. Much of this might be attributed to the
highly technical nature of the topic, and the manner in which it’s been introduced to the public. The EMP threat was introduced
to public attention, at least partly, through Hollywood. Movies such as GoldenEye (James Bond) and Ocean’s Eleven, with their
use of EMP-related technologies, may have served to blur the lines for the average person between reality and fiction.
Many individuals in government, industry, and the general population believe the threat is overstated or simply do not
understand it. Dr. George Baker, in his House testimony, identified some common misconceptions about EMP that either
downplay or exaggerate the threat, including the misrepresentation about the true impact on critical infrastructure and cost of
mitigations. He described the impact these misrepresentations have: “Downplaying the threats places EMP/GMD preparedness
on the back-burner compared to other effects. Exaggeration of the threats causes policy-makers to dismiss arguments,
ascribing them to tin foil hat conspiracy theories.”30
Our electric utilities expert echoed this sentiment, saying, “There is definitely an element [in electric utilities] of
misunderstanding the threat, i.e. they think it’s science fiction.”

Misalignment of Incentives for Private Sector and Government Stakeholders
Our electric utilities expert spoke to the lack of incentives within private sector utilities to address EMP vulnerabilities. One key
observation is that EMP is not a risk that utilities “own,” meaning it is neither something they cause nor are required by
regulation to provide reliability and resiliency against. This is especially true for nuclear HEMP, which utilities view as a national
security or defense responsibility.31 According to our expert, not owning the threat makes it difficult for utilities to put it into their
planning and strategies. Exacerbating the issue is the fact that the worst of these events are either extremely infrequent or have
never happened (and may never actually happen). Utilities are very good about protecting from lightning strikes, for instance,
because they happen every day and operators know how much damage they cause, how long it takes to make repairs, and the
economic costs. For EMP events, they must rely on modeling to assess impacts. Because of this, according to our expert,
utilities are far more focused on known threats with less uncertainty in the probability and consequences.

Government Ownership, Coordination, and Execution Problems
The final pillar of inaction for EMP protection appears to be an inability to coordinate and execute on the issue, largely due to
the size, scope, and complexity of the problem and ambiguity of ownership. The Commission’s recommendations, while directed




and actionable, carry no legislative or executive mandate. In the absence of a dedicated EMP lead at the Federal level,
confusion reigns and the Commission’s recommendations serve as FYIs rather than imperatives. George Baker summed up this
dynamic in his House testimony:
“To a major extent, the lack of progress in protecting our most critical infrastructure to EMP and GMD is that
the responsibility is distributed. There is no single point of responsibility to develop and implement a national
protection plan. Nobody is in charge. When I asked [NERC] about EMP protection, they informed me, ‘we don’t
do EMP, that’s a Department of Defense problem.’ The Department of Defense tells me, ‘EMP protection of
the civilian infrastructure is a DHS responsibility.’ DHS explained to me that the responsibility for the electric
power grid protection is within DOE since they are the designated Sector Specific Agency (SSA) for the energy
infrastructure. EMP protection has become a finger pointing, ‘ring around the rosy,’ duck-and-cover game. Our
bureaucracy has enabled gaps for addressing the difficult problems of EMP and GMD, resulting in no
substantive action to protect the nation. We have the classic Washington problem of issues that span
departments or fall between departments, which we’re all very familiar with, but then we add to that the
involvement of the private sector, without central leadership, we’re foundering. Because these catastrophes
can be continental in scale with everyone in trouble, and there’s nobody left to help, the ultimate solution, by
default, has fallen to the state and local levels. States are entitled to protect the safety, reliability and
adequacy of their electric grids, but most states expect the Federal government to provide leadership in
protecting the bulk power system. Local level preparedness is crucial, but we still need Federal top down
guidance to achieve a uniform, coordinated approach to the problem – to be able to triage, to standardize
protection methods across the states and localities. We know, and I’ve stressed, that we can’t protect
everything. Uniform guidance is needed to determine what needs to be protected and assign responsibilities.
Local jurisdictions need top-level guidance and information to understand what to do. The current state of
EMP protection is random, disoriented and uncoordinated. As we go forward, I suggest that Congress establish
a responsible party or agency to be the central whip for EMP preparedness. That would change the landscape
materially and make progress possible.”32
While this story is certainly not uncommon in our government, especially with the biggest issues, the ramifications of inaction on
EMP are tremendous. While some isolated progress has been made, much more is needed to protect America from the threats
of nuclear HEMP and severe solar weather GMD. Only through better education on and communication of the threat, regulation
that appropriately incentivizes industry to harden and prepare for EMP, and legislation that organizes and empowers leadership
at a Federal level can we truly degrade the EMP threat. In the absence of these steps, states will likely continue to take action
themselves, but due to the interconnectivity of the U.S. critical infrastructure system, this can only take us so far.




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