NERC’s Standards Committee agreed Dec. 13 to send a twice-rejected cold weather reliability standard to industry for another ballot round after the organization’s Board of Trustees made clear this week that it was prepared to take action on its own if the standard failed another vote. 

The EOP-012-2 (Extreme cold weather preparedness and operations) standard has been under development since February, after FERC approved its predecessor standard EOP-012-1 but ordered a revised version to be submitted within a year. Two ballot rounds have failed to produce enough industry support to submit the standard to the board; the most recent round ended with a 58% segment-weighted vote for approval, short of the necessary two-thirds majority. 

At the Standards Committee’s monthly meeting this week, held at NERC headquarters in Atlanta, members voted unanimously to grant a waiver to the ERO’s Standard Processes Manual shortening any additional formal comment and ballot periods for the standard “to as little as 10 days” from the usual 45, with ballots to be conducted during the last five days of the comment period. 

This action was urged by the board at its meeting on Dec. 12, with Chair Ken DeFontes warning that if the committee did not pass the waiver the board would invoke its authority under section 321 of NERC’s Rules of Procedure to approve the standard without a successful ballot. (See related story, NERC Board May Force Action on Cold Weather Standard.) While the board has never used this authority before, DeFontes said it could be necessary in order to avoid missing FERC’s February deadline. 

While no members objected to the shortened comment period, Marty Hostler of the Northern California Power Agency noted that reports by FERC and NERC on previous cold weather events have recommended a three-pronged approach to improving winter reliability. This approach consists of improved reliability standards, outreach to generator owners and operators, and market rule changes where needed; however, Hostler said most of the effort so far has been in the first two areas, with apparently little action on market rules. 

“I understand we’re up against a deadline here, but to my knowledge there has been nothing done about market rule changes,” Hostler said. “I know NERC doesn’t do that, but that’s one of the prime recommendations for helping reliability, and I think there needs to be something on that as well, because that will improve … reliability [somewhat] and not just rely strictly on standards all the time.” 

A NERC representative confirmed that the shortened ballot period for EOP-012-2 will begin in January, after the winter holidays. 

Accelerated Timelines Approved

EOP-012-2 was just one of the proposed standards for which the committee approved shortened comment and ballot periods on Wednesday, reflecting the group’s desire to shorten development timelines and reduce what Chair Amy Casuscelli called “an all-time high number of standards development projects in flight.” 

Three of the projects in question are operating under the timeline imposed in FERC’s Order 901, issued in October. The order directed NERC to submit to the commission over the next three years three tranches of standards to improve the reliability of inverter-based resources. (See FERC Orders Reliability Rules for Inverter-Based Resources.) 

The first tranche — covering disturbance monitoring data sharing and post-event IBR performance validation and correction — is due in November 2024. Jamie Calderon, NERC manager of standards development, told the committee that the ERO had identified three projects affected by the deadline: 

• • Project 2020-02 — Modifications to PRC-024 (Generator ride-through);  
  • Project 2021-04 — Modifications to PRC-002; and  
  • Project 2023-02 — Analysis and mitigation of BES IBR performance issues. 

For the first two projects, NERC staff proposed to authorize shortening the initial formal comment and ballot periods “from 45 days to as few as 25 calendar days.” Project 2021-04 was not included in this request because it has already had its initial formal comment period. NERC’s additional proposals, to authorize shortening additional formal comment periods to “as little as 15 days” and reduce the final ballot period from 10 days to five calendar days, applied to all three projects. 

Calderon acknowledged that the requests were being made far in advance of any of these projects having a draft standard to send out for ballot. She explained that because of the “very tight timeline” of FERC’s order, the ERO wanted to request the process waivers ahead of time to ensure the standard drafting teams will not need to request them later if needed. 

Committee members approved the proposals for all three projects, albeit with some minor wording changes: clarifying that the shortening of additional comment periods applied to calendar days, and authorizing reducing the final ballot period to “as few as five calendar days.” This change was introduced because members felt that the suggested wording would make the reduction to five days mandatory rather than optional. 

Members also authorized the process waiver for Project 2023-07 (Transmission system planning performance requirements for extreme weather) with the same changes as the previous three projects. In addition, they voted to authorize the initial posting of reliability standard CIP-007-X, the result of FERC’s order to develop standards requiring internal network security monitoring at high- and medium-impact cyber systems, for a 35-day formal comment and ballot period. 

Casuscelli Hands over the Reins

This week’s meeting marked Casuscelli’s retirement both as the chair of the committee and a member. Current Vice Chair Todd Bennett, of Associated Electric Cooperative Inc., was elected in September to succeed her, with Troy Brumfield of American Transmission Co. chosen to serve as vice chair. 

Casuscelli has served as chair for two consecutive two-year terms. During the meeting she recalled some of the challenges the committee has faced during her tenure, including the COVID-19 pandemic and the record workload that the ERO’s standards development teams are facing. She thanked members, along with NERC staff and trustees, for their support over the last four years, and said she “can’t wait to see what’s next under [the new] leadership.” 

“I have just a few final words for Todd before we adjourn,” Casuscelli added before delivering her last lines as chair. “Tag: You’re it.”