Assignment 3.1: Critical Infrastructure Partnerships and Resilience, Lessons From the 2021 Texas Power Outages (NIPP 2013 and NSM-22)
Using the FERC–NERC staff report on the February 2021 cold weather outages, NIPP 2013 and National Security Memorandum 22 (2024), prepare a 750–1,000-word analytical briefing for government and utility leaders on one documented coordination problem between natural gas and electric systems. Use clear headings for five areas:
- Infrastructure importance and the value of partnerships.
- Partner responsibilities and the NIPP, including one strength and one limitation of the NIPP approach.
- Improving collaboration through NSM-22, naming lead and supporting partners.
- Sustaining partnerships and accountability.
- Measuring results with two measurable indicators.
Go beyond summary, support conclusions with all three required resources, distinguish source findings from your own analysis and explain limitations and at least one implementation challenge.
Load shed cut power to gas facilities
Councils, shared priorities
SRMA, minimum requirements, info sharing
Exercises, agreements, after-action
Critical-load registry, fuel-related outages
Model response
Original example for study purposes (about 840 words). Briefing format. Findings from the FERC–NERC report are attributed; recommendations are my analysis.
To: State and utility leaders responsible for critical infrastructure preparedness
Subject: Protecting natural gas facilities from rolling blackouts in extreme cold
Coordination problem. During the February 2021 winter storm, the Electric Reliability Council of Texas (ERCOT) ordered 20,000 MW of rolling blackouts, the largest manually controlled load-shedding event in U.S. history, and more than 4.5 million people in Texas lost power (Federal Energy Regulatory Commission [FERC], 2021). The FERC–NERC staff found that 21.5% of natural gas production declines were caused by power outages at wellheads, gathering and midstream facilities, while fuel issues caused 31.4% of unplanned generating unit outages (FERC, 2021). In other words, electricity cut to gas facilities reduced the fuel supply that power plants needed, deepening the electricity shortage. The staff recommended guidance on identifying natural gas infrastructure that should be protected from rolling blackouts (FERC, 2021). This briefing focuses on that problem.
1. Infrastructure Importance and the Value of Partnerships
Natural gas and electricity are mutually dependent: gas-fired plants supply a large share of Texas generation, yet compressors, processing plants and many wells need electricity to operate. A failure in either system can cascade into the other, disrupting heating, water treatment, hospitals and communications and creating national security risks when defense, energy and transportation operations depend on the same grid. Because these assets are owned by many private companies and regulated by different agencies, no single organization can manage the risk alone. Partnership is necessary to identify which gas facilities are critical, share real-time conditions and agree on load-shed priorities before a crisis.
2. Partner Responsibilities and the NIPP
In this case, ERCOT directed load shedding; transmission and distribution utilities chose which circuits to cut; the Public Utility Commission of Texas oversees ERCOT and electric utilities; the Railroad Commission of Texas regulates gas production; gas producers and midstream companies operate the facilities; generators depend on fuel; and federal partners, including FERC, NERC and the Department of Energy as the energy sector’s lead agency, set standards and support coordination. NIPP 2013 organizes such partners through sector and government coordinating councils and a shared risk management framework that asks partners to set goals, identify infrastructure, assess risks, implement activities and measure effectiveness (U.S. Department of Homeland Security [DHS], 2013).
Strength: the NIPP’s voluntary partnership structure gives gas and electric owners a trusted forum to share sensitive operational information and agree on shared priorities, such as identifying critical gas loads. Limitation: because NIPP relies on voluntary collaboration, it provides no mechanism to require gas facilities to register as critical loads or to winterize, and ERCOT’s grid is largely outside FERC’s wholesale market jurisdiction (although NERC reliability standards still apply), so voluntary agreements may not be enforced when the cost of compliance is high.
3. Improving Collaboration Through NSM-22
NSM-22 builds on NIPP but emphasizes shared responsibility, minimum risk-based requirements, accountability and timely information exchange, and it assigns sector risk management agencies (SRMAs) as the day-to-day federal interface for each sector, with the Department of Energy serving as the energy SRMA (The White House, 2024). Applying these principles, I recommend:
- A mandatory critical gas load registry. State regulators (the Public Utility Commission and Railroad Commission) would lead, with gas operators registering facilities and utilities excluding them from rotating outages. This applies NSM-22’s call for minimum requirements where voluntary measures fall short.
- Joint gas-electric situational awareness during cold-weather alerts. ERCOT would lead, supported by pipelines and producers, sharing forecasts of gas supply and electric load several days before an event. NSM-22’s emphasis on timely, actionable information supports this.
- Federal technical support and cross-sector risk analysis. DOE as SRMA, with CISA as national coordinator, would analyze gas-electric dependencies and share lessons with other regions.
These recommendations target the documented cause, but they have limits: registering facilities does not keep them running if equipment freezes, and protecting more circuits leaves fewer to rotate, potentially lengthening outages for residential customers.
4. Sustaining Partnerships and Accountability
Partners should sign written agreements defining roles during cold-weather emergencies, hold an annual pre-winter planning meeting and conduct a joint tabletop exercise that simulates fuel shortages and load shedding. After each significant event, a corrective-action review should document what failed and assign owners and deadlines. Publishing summary results to regulators supports NSM-22’s accountability expectations. Challenge: companies may resist sharing commercially sensitive data or paying for compliance, so regulators must protect confidential information and consider cost recovery.
5. Measuring Results
- Critical-load registration rate: the percentage of gas production and processing facilities above a defined size that are registered and verified in utility load-shed plans. Utilities and the Railroad Commission would collect the data, and the Public Utility Commission would review it each fall, addressing gaps before winter.
- Fuel-related generation outages during cold events: the megawatts of gas-fired generation unavailable due to fuel supply problems, compared with 2021 baseline data. ERCOT would collect it, and the partnership’s after-action review would use the results to adjust registration rules and winterization priorities.
Together, these measures show whether partners are breaking the feedback loop that turned a cold snap into a statewide emergency.
References
Federal Energy Regulatory Commission. (2021, November 16). Final report on February 2021 freeze underscores winterization recommendations. https://www.ferc.gov/news-events/news/final-report-february-2021-freeze-underscores-winterization-recommendations
Federal Energy Regulatory Commission, North American Electric Reliability Corporation, & Regional Entity Staff. (2021). The February 2021 cold weather outages in Texas and the South Central United States.
The White House. (2024, April 30). National security memorandum on critical infrastructure security and resilience (NSM-22). Daily Compilation of Presidential Documents, DCPD-202400358.
U.S. Department of Homeland Security. (2013). NIPP 2013: Partnering for critical infrastructure security and resilience.
Tip: this example runs about 840 words. If you add a GAO finding from the optional resource, trim elsewhere to stay within the limit.
Frequently asked questions
Why did rolling blackouts make the gas shortage worse?
Some circuits cut during load shedding powered gas wells, gathering and processing facilities, so gas output fell just as power plants needed more fuel.
What does NSM-22 change from PPD-21?
It replaced PPD-21, renamed lead agencies as sector risk management agencies, made CISA the national coordinator and emphasized minimum requirements, accountability and information sharing.
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