NERC has asked FERC to clarify the data it wants to see in biennial informational filings on the ERO’s most recently approved cold weather standard, as well as whether the commission expects NERC to continue submitting the filings FERC ordered with previous versions of the standard (RD25-7).

FERC approved EOP-012-3 (Extreme cold weather preparedness and operations) at its September open meeting. (See  NERC Cold Weather Standard Gains FERC Approval.) NERC developed the standard in response to the commission’s directive ordering changes to the predecessor standard EOP-012-2. That standard itself was a revision to EOP-012-1, which FERC approved in 2023 while identifying numerous needed improvements.

Commissioners did not demand further changes to EOP-012-3 but did direct the ERO to submit follow-up filings every other year, beginning no later than October 2026 and ending in October 2034. The filings stem from the standard’s allowance for generator cold weather constraints — 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 must include:

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

NERC also must 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.
  • The reliability impact of cold weather constraint declarations and CAP extensions.

In an Oct. 17 filing, NERC said it shared “the commission’s desire to ensure that … EOP-012-3 is advancing generator cold weather preparedness for extreme cold weather conditions,” but expressed uncertainty about two elements of the order.

The first was FERC’s directive that NERC report the aggregate megavolt-amperes for approved constraint declarations. NERC acknowledged that its Rules of Procedure mention megavolt-amperes in the criteria for placing entities on the ERO’s Compliance Registry but observed that it analyzes generating units based only on their real power in megawatts. NERC also pointed out that EOP-012-3 does not reference megavolt-amperes.

To clear up this confusion, NERC requested that FERC clarify whether it must report by megavolt-amperes only, or if reporting the aggregate megawatts of approved constraints would suffice. If the commission insists on megavolt-amperes, NERC requested that commissioners specify why they chose this approach “so that NERC may better understand the basis for such a collection.”

NERC’s other request applied to the annual filings FERC directed in its approval order for EOP-012-1, which were to include a range of information on cold weather constraints and corrective action plans. Observing “significant overlap in some aspects of the information” to be collected in each order, NERC asked whether it could consolidate both reports into the biennial filing ordered for EOP-012-3, and whether this consolidated filing still would sunset in 2034.