High-voltage transmission towers against a sunset sky, representing critical utility infrastructure and the need for operational resilience.

Fragmented Contingency Plans, Amplified Risks: 5 Key Challenges in U.S. Utilities and How to Anticipate Them

In an increasingly demanding environment, marked by strict regulations, extreme weather events, and a critical dependence on digital infrastructure, utilities face the enormous challenge of ensuring operational continuity in the face of any incident.

However, many organizations still lack comprehensive and updated contingency plans, creating operational, technical, and reputational vulnerabilities that must be urgently addressed.

1) Lack of a documented and tested continuity plan

Many utilities still operate with fragmented or outdated plans that fail to consider the most likely current scenarios: cyberattacks, network failures, critical supplier interruptions, or extreme weather events.

“A contingency plan that isn’t tested regularly is almost as risky as not having one,” states a Microsoft directive on operational continuity. The company requires that all its business continuity and disaster recovery plans be tested, reviewed, and updated at least every 12 months.

2) Infrastructure dependent on single points of failure

Excessive consolidation of services in certain data centers or infrastructures without adequate redundancy leaves many organizations exposed. A power outage, fire, or cloud provider failure can trigger cascading effects. The lack of clearly defined failover scenarios increases the risk of prolonged disruptions.

3) Lack of interoperability between critical systems

Utilities often operate with a mix of legacy systems and modern cloud solutions. Yet many of these systems are not effectively integrated, making quick and coordinated recovery difficult. “In the middle of a contingency, every minute counts. If systems can’t talk to each other, recovery becomes chaotic,” warns Heather Adkins, Vice President of Security Engineering at Google.

4) Limited visibility and infrastructure monitoring

Having a unified, real-time view of infrastructure health is essential for fast action. Still, many utilities rely on partial dashboards that prevent early detection of incidents. Implementing integrated monitoring platforms and intelligent alerts is crucial to anticipate failures before they affect service.

5) An organizational culture not oriented toward resilience

Finally, one of the biggest challenges is cultural. In many utilities, operational continuity is still seen as a purely technical matter instead of a strategic, cross-functional responsibility.

The absence of regular training, drills, and clear protocols means that when a real contingency occurs, teams often fail to respond with the required speed and coordination.

Toward a prepared infrastructure

Overcoming these challenges requires a comprehensive approach that combines technology, processes, and culture. Organizations such as the Federal Energy Regulatory Commission (FERC) and the National Institute of Standards and Technology (NIST) emphasize the importance of formalized, tested, and auditable continuity plans as an essential part of utility operations.

The path toward resilience is not immediate, but each step strengthens institutional capacity, protects the service, and safeguards public trust.

Reliability standards for the electrical system (approved by FERC) may require utilities to have backup plans, recovery strategies, and operational continuity frameworks for critical failures or system disturbances.

Adopting standardized communication and operational practices—such as NAESB’s WEQ standards—helps ensure that different parts of the power system can interoperate more effectively during contingencies.

Regulatory compliance is a practical incentive for maintaining up-to-date contingency plans.

FERC Reference – Regulatory Requirements and Operational Resilience

The Federal Energy Regulatory Commission (FERC) sets and oversees the reliability standards for the U.S. wholesale electric system. These standards, developed in collaboration with the North American Electric Reliability Corporation (NERC), require utilities to demonstrate that they have formal procedures for operational continuity and contingency response.

FERC mandates that system operators implement measures ensuring rapid service recovery and protection of critical infrastructure from technical incidents, cyberattacks, or natural events.

(Source: Federal Energy Regulatory Commission – “Standards for Business Practices and Communication Protocols for Public Utilities,” Federal Register, February 2025.)

NIST Reference – Technical Guidelines for Continuity and Cyber Resilience

The National Institute of Standards and Technology (NIST) provides the most internationally recognized technical guidelines for designing continuity and cyber-resilient systems.

Its publication NIST SP 800-34 Rev. 1 outlines a structured approach that includes impact analysis, recovery strategies, periodic testing, and staff training as pillars of operational resilience.

Meanwhile, NIST SP 800-160 Vol. 2 Rev. 1 proposes design principles that enable organizations to anticipate, withstand, and recover from disruptions or cyberattacks, stressing that resilience should not be an afterthought but a core element of system architecture.

Together, NIST guidelines demonstrate that business continuity and security are not separate goals—they are two dimensions of the same organizational survival strategy.