With no industry pushback, regulators have a clear path to incentivize the deployment of proven technologies that can mitigate billions in annual losses and strengthen grid resilience.

In our previous article, “How to Prevent the Inevitable Collapse of the US Power Grid,” we warned of the very real risks to America’s electric grid from Ground-Induced Currents (GICs) and outlined a formal complaint we filed with the grid’s federal regulator—the Federal Energy Regulatory Commission (FERC)—urging protection against this very real threat. We also highlighted the roughly $10 billion in annual economic losses from GIC-induced harmonics from routine, low-level solar storms and the availability of a proven, low-cost GIC-blocking technology developed by the industry that is already being deployed internationally, including patent-infringing clones that have been deployed throughout China.  

Our formal request to FERC was simple: to authorize straightforward rate-based cost recovery so utilities have a clear incentive to assess and protect the roughly 6,000 vulnerable extra-high-voltage transformers from GICs using the international protection standard set by the International Electrotechnical Commission (IEC 61000-2-9, May 2025). 

That request was modest, grounded in science, and squarely in the public interest. It resulted in FERC opening Docket No. EL26-49-000 and inviting formal comments until March 30, 2026. 

Industry Silence Signals a Rare Opening for Grid Security Reform

For the first time in more than a decade, not one utility, nor any major utility lobbying organization, chose to oppose a complaint filed by the Center for Security Policy and Secure the Grid Coalition. Neither the Edison Electric Institute (EEI), the American Public Power Association (APPA), nor the National Rural Electric Cooperative Association(NRECA) submitted comments opposing the petition. Their decision to remain silent on the substance is noteworthy and, we believe, constructive in the regulatory world as a sign of assent. 

While the North American Electric Reliability Corporation (NERC), in its March 30, 2026, Motion to Intervene, requested that FERC dismiss our complaint on technicalities, it importantly raised no objection to the facts we presented or the relief we sought on behalf of the American public.  

This is the first time that a major grid-security complaint from our Secure-the-Grid Coalition has gone unopposed by the nation’s electric utility industry lobbying complex. 

In the past, when members of our Coalition lodged justifiable complaints to FERC regarding gaps in physical security, cybersecurity, supply chain security, cold weather preparedness, and transparency, industry lobbying groups actively opposed the recommendations, and FERC ultimately dismissed our complaints. 

The absence of opposition this time creates a genuine opportunity for progress.

Federal Agencies, Labs, and Industry Provided Critical Validation to the Field-Tested Solution

When it comes to addressing the GIC threat to the grid, there are many positive steps that have already been taken by the electric industry, the Department of Energy (DOE), Idaho National Laboratory (INL), the Electric Power Research Institute (EPRI), the American Transmission Company (ATC), the Western Area Power Administration (WAPA), and the Tennessee Valley Authority (TVA). Utilities have responded constructively to certain parts of NERC’s GIC protection standard (TPL-007-4) by building detailed direct current (DC) circuit models of the grid, installing GIC monitors at numerous substations, and continuing to refine their understanding of geomagnetic disturbances. These efforts represent real progress in awareness and preparedness.

Similarly, DOE and its national laboratories have provided critical validation of the technological solution that can protect our grid from GICs. In 2012, Idaho National Labs, working with the Defense Threat Reduction Agency  (DTRA), successfully live-grid tested SolidGround. In his 2018 testimony to the US Senate Homeland Security & Governmental Affairs Committee, Scott McBride, the Infrastructure Security Manager for National and Homeland Security at Idaho National Laboratory, testified: “A mature, tested and validated technology has been developed and represents one potential solution to protect HV [High Voltage] and EHV power transformers from the threat of both GMD’s and EMP’s. The EMP hardened transformer Neutral Blocking Device (NBD) is designed to provide automatic protection for HV and EHV transformers against GMD and EMP events – when GMD or EMP induced currents in a transformer are detected.” 

He added that “The device provides a metallic path to solidly ground the transformer during normal operation and an Alternating Current (AC) effective grounding path for the transformer for only short periods (i.e. a few minutes to hours) when a solar disturbance (GMD) or an EMP event is impacting the earth.  Power grid modeling and studies have shown that neutral blocking in a power grid provides significant reductions in reactive power (VAR) consumption and Ground Induced Current (GIC) harmonics as well as protection against protective relay mis-operations. Additionally, NBD’s enhance the protection of Generator Step-Up (GSU) transformers at hydro-generation facilities which can provide important black-start resources for a power grid.”

The “mature, tested and validated technology” is known as SolidGround, which was developed by Emprimus in conjunction with the Department of Energy and the utility industry. The technology has been installed on several transformers at the 345 kilovolt (kV) and 500kV level for years, with 182 automatic operations successfully blocking GIC during solar events. Oak Ridge National Laboratory published two detailed analyses (2020 and 2025/2026) confirming that typical capacitance values used in SolidGround do not cause adverse effects on distance relays or grid stability. DOE also collaborated with EPRI, WAPA, and TVA on field installations and monitoring—a milestone that deserves recognition.

EPRI’s April 2019 technical report, “High-Altitude Electromagnetic Pulse and the Bulk Power System: Potential Impacts and Mitigation Strategies,” further underscores the effectiveness of capacitive neutral-blocking devices such as SolidGround for blocking E3 High-Altitude Electromagnetic Pulse (HEMP) -induced GIC (see Figure 5-12 and Section 5). It should be noted that collaborative inputs from EPRI on these various DOE projects assisted in the final design of the SolidGround solution. Multiple industry presentations have referenced EPRI’s work, including:

• PowerWorld / EMPRIMUS joint modeling presentations on GIC and neutral blocking (2013)  
• American Transmission Company (ATC) / EMPRIMUS co-authored updates on ongoing SolidGround performance (2017–2019) 
• EPRI Project Manager Randy Horton’s presentation to the NERC EMP Task Force (June 2019)  
• Secure the Grid Coalition in-person presentations before the Secretary of Energy Advisory Board (2022)

These contributions show a shared commitment to better understanding and addressing GIC risks.

A History of Research and Deployment Sets the Stage for Policy Action 

Given this constructive history, FERC now has a clear and compelling basis to approve rate-based cost recovery for utilities that voluntarily assess their transformers and install proven GIC protection to the 85 volts per kilometer (V/km) international standard. Such approval would eliminate approximately $10 billion in recurring annual economic losses, permanently harden the grid against both severe solar storms and E3 HEMP, and provide the “firm foundation” that is essential for the Trump administration’s “Speed to Power” initiative and nuclear expansion.

We believe this moment presents a genuine opportunity for collaboration. The industry has demonstrated willingness to comply with modeling and monitoring requirements under TPL-007-4. Extending that same constructive approach to cost recovery would align private investment with the public interests, national strategic interests, and strengthen the resilience of every critical infrastructure that depends on reliable power.

The Record Is Clear. The Time for Action Is Now.

Thus far, it is unclear how FERC will rule on Docket EL26-49-000. We remain hopeful that this regulatory authority—our nation’s “Supreme Court” on Energy—will seize this unique opening to incentivize protection at a level that matches hard science to the hard threat. 

The full record surrounding Docket EL26-49-000—and particularly the electric industry’s lack of opposition to it—should make it clear to FERC’s Commissioners that the technology is proven, the cost is modest and recoverable, and the benefits of GIC protection are shared by every American. 

Thus, a FERC decision to help the industry fund this protection is a practical, commonsense step that can and should be taken now. 

About the Authors: Tommy Waller, Douglas Ellsworth, and Michael Mabee

Lt. Col. Tommy Waller is the president & CEO of the nonprofit Center for Security Policy. Waller retired from the US Marine Corps after two decades of service in both active duty and the reserves as an Infantry and Expeditionary Ground Reconnaissance officer with deployments to Afghanistan, Iraq, Africa, and South America, and with cross-assigned service to the US Air Force’s Electromagnetic Defense Task Force (EDTF). His formal education includes numerous military schools and colleges, a BA in International Relations from Tulane University, and executive education from the Wharton School. In addition to running the Center for Security Policy, he also manages the nationwide bipartisan Secure the Grid Coalition.

Douglas Ellsworth is a senior fellow at the Center for Security Policy and serves as the co-director of the Center-sponsored Secure the Grid (STG) Coalition—an ad hoc group of policy, energy, and national security experts, legislators, and industry insiders who are dedicated to strengthening the resilience of America’s electrical grid. Through the support of the Center for Security Policy, the STG Coalition aims to raise awareness about the national security threat of grid vulnerability and encourage the steps needed to neutralize it. The STG Coalition brings a wide variety of expertise in cybersecurity, physical security, public policy and expressly serves the public interest. 

Command Sergeant Major Michael Mabee (US Army Ret.) retired from the federal government in 2026 with 45 years to the day under oath to defend the Constitution. He is the author of The Civil Defense Book: Emergency Preparedness for a Rural or Suburban Community and has conducted public interest research on the security of the electric grid because of the absolutely vital role of this infrastructure in undergirding the very survival of our country. Michael has been featured on 60 Minutes, quoted by The Wall Street Journal, The Washington Post, CNN, Newsweek, and many other media outlets and publications on grid security. Michael has intervened and submitted testimony in over 200 federal dockets on electric grid security issues. He has participated in federal rulemaking related to grid security and has written the leading reference empowering communities to prepare for and survive a long-term power outage.  He continues to write and speak about emergency preparedness for a long-term blackout.

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