In a relatively light monthly conference call Nov. 18, NERC’s Standards Committee unanimously agreed to reject a standard authorization request that would have exempted nuclear generators from the reporting requirements of reliability standard EOP-004-4 (Event reporting).

The Nuclear Energy Institute (NEI) proposed the SAR in March, with the goal of making EOP-004-4 consistent with recent changes to the Department of Energy’s DOE-417 form, used by generator owners, generator operators, balancing authorities and reliability coordinators to report electric emergency events and disturbances.

Reportable events include many cyber and physical security events, islanding, system-wide voltage reductions of 3% or more and complete operational failure or shutdown of the transmission or distribution system.

Similarly, EOP-004-4 requires GOs, GOPs, BAs, RCs and other registered entities to report certain events to the ERO, including damage to or destruction of a facility, physical threats to a facility or control center, generation and transmission loss, and complete loss of off-site power to a nuclear generating plant. Entities may use either DOE-417 or the form attached to the standard to report incidents.

Earlier in 2025, DOE-417 was updated to exempt operators of commercial nuclear plants regulated by the Nuclear Regulatory Commission (NRC) from reporting requirements. NEI’s SAR (page 15 of the agenda) proposed revising EOP-004-4 to provide a similar exemption, similar to that found in CIP-008-6 (Cybersecurity — incident reporting and response planning). That standard excuses cyber assets at facilities regulated by the NRC and its Canadian equivalent from reporting cybersecurity incidents to NERC.

However, NERC staff was “very concerned” about the proposal, NERC Manager of Standards Development Sandhya Madan told SC members, because it would eliminate “NERC’s only mandatory source of physical event incident reports for nuclear power plants.” She also said the reporting requirement is not duplicative, contrary to another of NEI’s arguments, because NERC does not have another route for such information.

Jennie Wike, compliance lead at Tacoma Public Utilities, pressed Madan on this point, asking whether keeping the reporting requirement for EOP-004-4 would run afoul of the Trump administration’s push to “eliminate duplicate requirements across government agencies.” In response, Madan repeated that while the NRC might consider the requirement in DOE-417 to be duplicative because the NRC already receives such reports, NERC does not have any other avenue for GOs and GOPs to submit the information.

Paul MacDonald, director of reliability standards, compliance and enforcement for the New Brunswick Energy and Utilities Board, reminded attendees that the standard also applies to Canadian utilities that are not subject to the NRC. He said the information was “important … for NERC to analyze” the behavior of nuclear plants during grid events.

Despite her earlier questions, Wike made the motion to accept NERC staff’s recommendation and reject the SAR. In accordance with NERC’s Rules of Procedure, the SC must provide a rationale for the rejection to NEI within the next 10 days, which Chair Todd Bennett volunteered to do.

INSM Standard Posting Approved

The SC agreed to authorize the posting of proposed standard CIP-015-2 (Cybersecurity — internal network security monitoring [INSM]) (Page 23 of the agenda) for an initial 45 calendar day formal comment and ballot period. Ballot pools will be formed in the first 30 days, and ballots will be conducted in the last 10 calendar days of the period.

The standard was developed under Project 2025-02 (Internal network security monitoring standard revision), in accordance with FERC’s June 26 order to modify the new INSM standard CIP-015-1 by extending its reach. (See FERC Approves NERC’s Proposed INSM Standard.) FERC directed NERC to file, within the next 12 months, a new standard that extends INSM implementation to electronic access control or monitoring systems, along with physical access control systems, outside a utility’s electronic security perimeter — the electronic border around its internal network.

Presenting the draft standard, NERC Manager of Standards Development Alison Oswald said the standard drafting team “has worked very quickly” to respond to FERC’s directive, and that “initial feedback … on this proposed draft has been very positive.” This motion passed unanimously.

New Members Elected

Finally, Standards Developer Dominique Love presented the results of the elections for new SC members that concluded Nov. 3. Seven members have been confirmed to begin two-year terms beginning Jan. 1, 2026:

• • Segment 1: Brandon Weese, NERC compliance manager at American Electric Power
  • Segment 2: Jamie Johnson, infrastructure compliance manager at CAISO
  • Segment 3: Claudine Fritz, senior manager for the principal compliance program at Exelon
  • Segment 4: William Pezalla, vice president for regulatory affairs at Old Dominion Electric Cooperative
  • Segment 5: Terri Pyle, head of utility operational compliance and NERC compliance at Oklahoma Gas and Electric
  • Segment 9: Paul MacDonald

No nominee for the two-year term in Segment 8, or the special election for a one-year term in Segment 5, received a simple majority, so NERC will conduct a runoff election for both seats in early December, Love said. In addition, the nominee for Segment 7 withdrew, so another nomination period is required.

Segment 10, representing regional entities, has an alternate election procedure. NERC will announce the nominee at a later date.