Eight months after launching the Modernization of Standards Processes and Procedures Task Force (MSPPTF), NERC is seeking feedback from industry on the task force’s draft recommendations to help the ERO’s standards development meet the pace of change on the grid.

NERC’s Board of Trustees created the MSPPTF in February in light of the rapidly evolving risk environment, which ERO leaders said has made it increasingly difficult for the organization’s consensus-based approach to keep up with new threats to grid reliability. (See NERC Leaders Highlight Canada-US Collaboration.) Trustees directed the task force to submit its final recommendations at the board’s February 2026 meeting in Savannah, Ga.

The draft recommendations, published Oct. 21, were developed by the MSPPTF with the help of comments received on a draft white paper released in July. (See NERC Task Force Members Share Standards Modernization Progress.) In the introduction, Chair Greg Ford and Vice Chair Todd Lucas explained that the team followed three guiding principles when developing the proposals:

• • Transform and modernize the process of standard development.
  • Find opportunities to save time and remove redundant steps.
  • Ensure due process is followed, competing interests are balanced and stakeholders are able to provide input.

When drafting the recommendations, the MSPPTF divided the standards development process into three stages. The team’s proposals were organized around these divisions.

Structuring the Initiation Phase

First is the standard initiation phase, which begins when a request to develop a standard is submitted to NERC and ends when the request is approved to begin drafting. Currently such standard authorization requests (SARs) may come from any entity or individual, including NERC committees or staff. SARs may be received and processed at any time of year.

NERC’s Standards Committee reviews SARs to determine if they are ready for development and may accept them, reject them for good cause, remand them for further work or delay action for consultation with other committees. Accepted SARs are posted for industry comment; following this, a drafting team is appointed to revise the SAR and resubmit it to the SC. If the committee approves the revised SAR, drafting may begin.

The MSPPTF found that this process is unclear, lacking requirements for the information needed to initiate development. The current process also lacks a clear framework for prioritizing and vetting SARs and does not provide opportunities to build industry support for the project early on. These shortfalls mean the initiation phase takes too much time and resources, the task force said.

To address these issues, task force members proposed a four- to six-month review and prioritization process to take place twice a year. This process would involve:

• • an open period to request new standard development projects;
  • review of requests by NERC’s Reliability and Security Technical Committee;
  • workshops and stakeholder feedback by a new subcommittee of the Reliability Issues Steering Committee (RISC);
  • production of a document outlining all standard requests received by the new subcommittee; and
  • development of term sheets for each project outlining the risk to be addressed and basic elements of the standard to be developed.

Standard initiation requests involving directives from FERC or NERC’s board would follow this process in a compressed time frame.

Streamlining Drafting

The second phase is drafting, which begins when an SAR is approved and ends when the standard drafting team proposes a first draft standard.

Drafting teams currently are composed of volunteers from industry and other stakeholders, with support from NERC staff. Drafting often overlaps with the third phase — balloting — because if a draft standard fails to pass a ballot round, it is returned to the drafting team for revisions.

Task force members said the current process is inefficient, with drawn-out timelines leading to lack of urgency, and that it is a substantial time commitment for volunteers. The use of multiple ballot rounds can also overwhelm drafting team members who lose focus on the overall goal while responding to individual comments and questions, and they slow down the drafting process with frequent stops and starts. Members even said some stakeholders vote “no” on the first draft standard unnecessarily, because they believe this is the only way to have their comments fully considered.

Under the task force’s draft recommendation, the new RISC subcommittee from the initiation phase would drive the drafting stage. This subcommittee would form a panel of subject matter experts covering a wide range of topics to help review and refine draft standards, thus reducing the need to recruit outside talent for standard drafting teams.

The MSPPTF also recommended giving NERC staff a greater day-to-day role in standards development. Possible tasks include creating “version zero” draft standards, with technical justification and supporting compliance elements, to help the drafting team get started. Artificial intelligence could be used to assist with this process, though the authors acknowledged that “human oversight will be essential to ensure that any AI-generated output meets quality expectations.”

The final key part of the task force’s drafting recommendations is to improve the stakeholder feedback process, which currently revolves around balloting and comment periods. Task force members envisioned a process that begins with the “version zero” draft standard; this draft would be posted for a 45-day comment period with a nonbinding straw poll to gauge initial industry support. NERC staff and the SME panel would then review comments with the help of an AI summary and analysis tools and prepare a written response.

If needed, a second draft of the standard would be posted for a 30-day comment period and straw poll. This time period could be shortened for high-priority projects. After a “good-faith effort” by the project team to address all concerns, the draft would be posted for a ballot to confirm industry consensus.

Greater Clarity in Balloting

The last set of draft recommendations concerns the balloting phase, in which proposed standards are voted on by the registered ballot body (RBB), comprising representatives from NERC’s 10 industry segments. A separate ballot pool is created from the RBB with each draft standard.

MSPPTF members found that this process does not provide enough accountability; individual voters may take positions opposed to their companies’ positions as expressed by management. The short signup period for ballot pool members also forms a barrier to stakeholder participation, as does the growing number of standards projects, each of which needs its own ballot pool.

Draft recommendations for this process, in addition to implementing a single 30-day ballot period, include limiting voting eligibility to persons or entities that participated in one or more comment periods for the draft standard and are active members of the RBB. Failure of the ballot to confirm consensus would lead to review by the RISC subcommittee, which may send it for further revisions and another ballot; alternatively, the subcommittee could end all further work on the project or recommend other action.

The MSPPTF also suggested restructuring the RBB to rebalance the influence of each industry segment, for example by expanding the weight of Segment 2 (RTOs and ISOs) while combining the “chronically undersubscribed” Segments 7 and 8 (large and small electricity users). This would result in six segments:

• • transmission owners;
  • RTOs and ISOs;
  • load-serving entities and transmission-dependent utilities;
  • electric generators;
  • electricity end users; and
  • governmental and nonprofit public interest entities.

The task force called for comments to be submitted via NERC’s draft recommendations feedback form. Responses must be sent by 12 p.m. ET on Nov. 10.