41 8. OTHER IMPLEMENTATION ISSUES After successfully designing and implementing a resiliency program, the Utility Infrastructure Resiliency Playbook (Playbook) offers suggestions on additional concepts or implementation issues for consideration. Dynamic Regulatory Environment – The Federal and State regulatory environment remains highly dynamic and monitoring the development of this environment is critical. Federal Energy Regulatory Commission (FERC) and State Public Utility Commission (PUC) will continue to search for solutions to improve system reliability or resiliency. Climate Change Complications – The potential for climate change related impacts to electric system reliability and resiliency continue. If these changes manifest, it will result in different risk and risk context for the management of electric systems. As an example, global mean sea level has already risen 7 to 8 inches since 1900, and the potential inundation of coastal cities will present additional challenges to undergrounding strategies. Physical Security - the potential for attacks to the grid are a continuing threat including theft and vandalism. The undergrounding of electric assets may both reduce and change the risk exposure to these assets in ways not well understood or experienced. Geomagnetic Disturbances (GMD) & Electromagnetic Pulse (EMP)– Electric systems are subject to geomagnetic or electromagnetic disturbances and while not well known or recognized, North America has experienced multiple impacts including a severe 1859 geomagnetic storm that significantly disrupted the telegraph system. While the undergrounding of system assets will protect them from some of these impacts it increases exposure to other aspects. In addition, all undergrounding assets remain connected to above ground assets that are susceptible. Undergrounding Impact Measures – The vast majority of reliability or resiliency measures are set up to assess total system performance. Regional levels or targeted metrics have not been well defined and performance data on capabilities are not regularly collected by many utilities. Because of the targeted nature of many underground strategies, regional or other targeted metric development will continue to require attention and effort. Effective Communications – As is described in Step 5 IMPLEMENTATION, communications with 1) Regulators or Legislators to seek approval; 2) Stakeholders affected by construction activity; and 3) Public, Regulators, and Legislators are critical. These communications will only become more important in the future and continued work on communication methods and concepts are required. Resiliency programs and particularly undergrounding strategies deliver significant benefits, especially when highly targeted. Given the dynamic nature of the utility, climate, and related environments, changed and new implementation issues will continue to present. This Playbook is designed to help electric investor-owned, municipal, and co-op utilities address these obstacles and to adapt to the dynamic and changing environment.
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