At its monthly open meeting Sept. 18, FERC approved the latest version of NERC’s cold weather preparedness standard while ordering follow-up informational filings on progress with its adoption.

In a press conference after the meeting, Chair David Rosner said that grid reliability remains “job No. 1” for the commission and that he was “really pleased” that FERC was able to advance the cold weather standard and other reliability items on the agenda. (See FERC Tackles Cybersecurity in Multiple Orders.)

NERC submitted EOP-012-3 (Extreme cold weather preparedness and operations) on April 10 in response to the commission’s directive that it develop “targeted modifications” to its predecessor, EOP-012-2 (RD25-7). FERC had called for the ERO to clarify the term “generator cold weather constraint” (situations in which a generator owner may declare that a specific freeze protection measure would result in a net loss of reliability on the grid) and ensure that the ERO confirms the validity of each constraint, along with clarifying requirements around corrective action plans.

In the new standard, NERC proposed a new, clearer definition for generator cold weather constraints that removed ambiguous references to “cost,” “reasonable cost,” “unreasonable cost” and “good business practices.” An attachment to the standard provides examples of acceptable constraint declarations, such as a case in which “the cost of retrofitting a generating unit would be unduly burdensome such that it would retire prematurely or cancel plans to finish the development of a new generating unit.”

The standard also introduces the concept of a compliance abeyance period for the requirement that GOs calculate the extreme low temperature for their generating units, a move intended to allow some flexibility in the initial application of this requirement. During the abeyance period NERC will “monitor the implementation of this requirement and identify, as appropriate, any revisions to the extreme cold weather temperature formula,” FERC said.

The commission indicated it would approve the standard without any of the modifications called for by the Union of Concerned Scientists, which claimed the cold weather constraint language remained too subjective. (See NERC Replies to UCS’ Cold Weather Standard Criticism.) FERC said the standard was “consistent with commission guidance to provide a limited set of defined circumstances” in which constraints could be granted.

However, the commission did direct the ERO to collect and submit to FERC informational filings every two years, starting no later than October 2026 and ending in October 2034. The filings must include:

• • the number of cold weather constraint declarations submitted to each regional entity;
  • the number of declarations approved, and their aggregate megavolt-amperes; and
  • a summary of the rationales provided for approved declarations.

NERC must also submit a narrative analysis in the filing addressing:

• • whether reliability coordinators, transmission operators and balancing authorities are notified in a timely fashion of constraint declarations and extensions to corrective action plans (CAPs);
  • the reliability impact of allowing 36 months to correct freeze-related issues, rather than a shorter time frame;
  • whether compliance enforcement authorities interpret and apply the constraint declarations approval process;
  • whether constraint declaration criteria are adequately defined and understood by registered entities; and
  • the reliability impact of cold weather constraint declarations and CAP extensions.

The standard will take effect Oct. 1. This is a departure from NERC’s request that the standard take effect either that date or three months after regulatory approval, whichever is later. That plan would have resulted in an effective date in December, but FERC said that the earlier date would allow the standard to be in effect before the upcoming winter.

The commission also observed that “industry was involved in NERC’s standard development process and was made aware of pending changes,” meaning the new requirements should not be a surprise for registered entities.