![handle is hein.journals/jregb37 and id is 1 raw text is:
Electric Power Resilience: The Challenges for Utilities
and Regulators
Kenneth W. Costellot
Few people doubt that the United States will continue to experience long-
lasting electric power outages affecting a large number of people and
businesses (e.g., outages from Superstorm Sandy, Hurricane Maria in Puerto
Rico, and severe hurricanes in Florida).' Some industry observers believe that
the resilience of the U.S. electric-power network is deficient, and if industry
spends additional funds on improving its resilience, the benefits would
outweigh the costs.2
Customers, the media, and the public have taken more interest in
scrutinizing utilities' responses to weather-related disasters and cyberattack
threats.3 There is a full-court press at the federal, state, and local levels to
bolster the resilience of electric power.4
The common perception is that the benefits are too large to ignore. This
belief seems plausible on its surface. After all, the damages from a long power
T Regulatory economist/consultant. Previously employed by the National Regulatory
Research Institute, the Illinois Commerce Commission, the Argonne National Laboratory and
Commonwealth Edison Company. I want to thank Robert Bradley, Devin Hartman, Ross Hemphill, and
Peter Larsen for their comments on an early draft. I wish to express my deep appreciation to the editorial
staff of the Yale Journal on Regulation, especially Blake Shultz and DJ Sandoval, for their thorough
review and insights that enhanced the quality of this Essay.
1. See Resilience Strategies for Power Outages, CTR. FOR CLIMATE & ENERGY SOLS. (Aug.
2018), https://www.c2es.org/site/assets/uploads/20 18/08/resilience-strategies-power-outages.pdf
[https://perma.cc/NZD9-ZV68].
2. See Enhancing the Resilience of the Nation's Electricity System, NAT'L ACADS. SCI.,
ENGINEERING, & MED. 13 (2017), https://www.nap.edu/catalog/24836/enhancing-the-resilience-of-the-
nations-electricity-system [https://perma.cc/5SD3-8MC6]. Extreme weather and distribution-level
problems are the primary factors in the duration of electric power interruptions, with bulk generation
shortfalls accounting for only a tiny number of customer outages, especially extended outages. Thus, the
emphasis is on spending more money at the distribution level to enhance resilience. See Alison
Silverstein et al., A Customer-focused Framework for Electric System Resilience, GRID STRATEGIES,
LLC 14-18 (May 2018), https://gridprogress.files.wordpress.com/2018/05/customer-focused-resilience-
final-0501 18.pdf [https://perma.cc/V4JY-JE4P].
3. See CONG. RESEARCH SERV., IN10895, ELECTRIC RELIABILITY AND POWER SYSTEM
RESILIENCE (2018), [https://perma.cc/R57Q-3G7G]; Before and After the Storm, EDISON ELECTRIC
INST., at v. (Mar. 2014),
http://www.eei.org/issuesandpolicy/electricreliability/mutualassistance/Documents/BeforeandAftertheSt
orm.pdf [https://perma.cc/KV3Y-ABMD]; Hardening the Grid: How States Are Working to Establish a
Resilient and Reliable Electric System, NAT'L CONF. STATE LEGISLATURES (Apr. 2018),
http://www.ncsl.org/Portals/1/Documents/energy/HardeningGrid 1_32298.pdf [https://perma.cc/EV45-
CU7S].
4. See Order Terminating Rulemaking Proceeding, Initiating New Proceeding, and
Establishing Additional Procedures, FED. ENERGY REGULATORY COMM'N (Jan. 8, 2018),
https://www.ferc.gov/CalendarFiles/20180108161614-RM18-1-00O.pdf [https://perma.cc/6SQB-YCB2].
See also Before and After the Storm, supra note 3, for a listing of state activities addressing issues
related to electric power resilience.
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