Uncertain Energy Availability

Designated as an EXTREME risk

A reliable bulk power system requires an instantaneous and precise balance: supply must perfectly match demand every second to prevent system instability or collapse. This has historically been achieved by planning sufficient dispatchable generation and reserves (supply) around predictable load patterns (demand). Integrating weather dependent, intermittent, and finite duration resources (wind, solar and battery storage) complicate this precise balance.​

At the same time, electricity demand is increasing rapidly and becoming harder to forecast. Massive new 'hyperscale' loads—primarily data centers that require a constant supply of reliable power—are driving much of this growth.

Across the MRO region, accelerating retirements of dispatchable power plants before adequate replacement energy is available, limited transmission capacity, and barriers to timely deployment of new infrastructure are increasing the risk of energy shortfalls.

Recent reliability assessments and bulk power system events underscore the need for new energy adequacy metrics, improved planning standards, and careful management of retirements to ensure sufficient dispatchable resources remain available.

Nation-State Threat

Designated as a HIGH risk

Rising geopolitical conflicts have dramatically increased the volume and sophistication of nation-state threats targeting North American critical infrastructure, including the bulk power system.​ These well-resourced threat actors pose a significant and strategic cyber threat aimed at undermining military, economic, and political capabilities.

They demonstrate high levels of persistence within Information Technology (IT) and Operational Technology (OT) environments and often use “Living Off the Land” techniques to carry out attacks that avoid detection from installed security software tools. Recent campaigns—such as the China-linked Volt Typhoon and Russia’s Sandworm attacks on European grids—showcase the potential for coordinated cyber and physical strikes on critical infrastructure.

While existing NERC Critical Infrastructure Protection standards offer a foundation of defense-in-depth protection, the evolving landscape requires a more proactive approach that includes enhanced internal network monitoring, improved detection on OT systems, and stronger preparedness for coordinated, large-scale cyber events.

Generation Outages During Extreme Cold Weather

Designated as a HIGH risk

Recent extreme winter storms—including Uri (2021), Elliott (2022), and major events in early 2024, 2025, and 2026—severely strained both electric generation and natural gas systems. These events caused elevated outage rates and, in some cases, unprecedented firm load shedding to maintain electric grid stability. MRO staff participated in the expert analysis of these events that exposed vulnerabilities like insufficient winterization of infrastructure, a growing reliance on “just-in-time” natural gas delivery, and tightening operating margins due to the retirement of dispatchable resources.

Unplanned generation outages during major winter storms have been several times higher than planned seasonal averages. While NERC cold weather preparedness standards and industry-wide initiatives are strengthening grid resilience, extreme winter weather remains a primary reliability risk. The system is particularly vulnerable when high outage rates coincide with constrained fuel supplies and limited electricity import capabilities.

Supply Chain Compromise

Designated as a HIGH risk

A supply chain compromise occurs when malicious or defective hardware, software, or services are introduced into utility systems before deployment. This can happen through intentional manipulation by threat actors or weak security practices at the vendor level. Several trends have heightened this risk to the bulk power system:

• There is growing reliance on a small number of common third-party providers, which creates single points of failure.
• At the same time, utilities often have limited visibility into third-party hardware/software development, manufacturing, and security protocols.
• The rapid deployment of wind, solar, and battery technologies introduces new software-heavy components into the grid, expanding the potential attack surface.

Recent incidents—including compromised open-source software, ransomware delivered through managed service providers, and large-scale software update failures—demonstrate how a single vendor vulnerability can trigger widespread operational disruptions.

Inadequate Inverter Performance and Modeling

Designated as a HIGH risk

Advanced technologies have introduced new risks to power grid planning and operations. Inverter-based resources (IBRs)—such as wind, solar, and battery storage—rely on programmable software, unlike traditional electricity generators that provide a physical response to grid stress. Inverter-based loads, primarily data centers, add another dimension to this risk because of their scale and concentrated electricity consumption.

Limited operational experience, combined with insufficient and incorrect modeling, makes it difficult for system planners and operators to accurately forecast how inverters will behave during grid disturbances. Past events have shown that poorly coordinated or misconfigured inverters can “trip” or disconnect simultaneously from the grid. This leads to abrupt, large-scale shifts in electricity supply or demand that can destabilize the entire system.

While new NERC standards are being developed and implemented to improve IBR modeling accuracy and performance, continuous monitoring, industry coordination, and new or enhanced technical standards are essential to maintaining bulk power system stability.

Material and Equipment Unavailability

Designated as a HIGH risk

Rising demand to replace aging infrastructure and build new generation and transmission has strained the global electrical equipment supply chain beyond its current manufacturing capacity. Utilities are facing unprecedented competition for electrical equipment, primarily driven by the rapid expansion of large-scale data centers. This has led to much longer lead times for critical components like power transformers and circuit breakers, which limits utilities’ ability to quickly replace failed assets or address security vulnerabilities.

These delays heighten reliability risks by keeping critical system components out of service for longer periods and delaying major generation and transmission projects needed to meet rising demand. As equipment availability becomes a strategic risk rather than just a procurement hurdle, mitigation now depends on spare equipment sharing, strong vendor relationships, and proactive inventory management.

Malicious Insider Threat

Designated as a HIGH risk

A malicious insider—including employees, contractors, or vendors with authorized access—poses a unique risk to system reliability. Unlike external attackers, insiders possess legitimate credentials, proximity to critical assets, and deep institutional knowledge of system vulnerabilities. Insiders may be motivated by professional dissatisfaction, ideological beliefs, or financial gain. They may act independently or in coordination with external actors to conduct cyber or physical attacks on corporate networks, operational control systems, and bulk power system assets. Heightening this risk are:

• A growing dependency on external contractors and vendors expands the number of individuals with high-level access.
• Ongoing social and political unrest, influencing individual motivation and increasing the likelihood of ideological sabotage.
• Ineffective perimeter defenses, as insider activities easily blend in with normal administrative or maintenance tasks.

While existing NERC CIP standards provide defense-in-depth protection for high- and medium- impact assets, gaps remain for low impact assets. To address this, new requirements—specifically CIP-015-1 (Internal Network Security Monitoring)—are being implemented to improve detection, response, and recovery from unauthorized internal activity. Effective mitigation depends on strong insider threat programs, security-focused organizational culture, least-privilege access controls, network segmentation, and proactive monitoring.