NERC will go back to work on another revision to its most recent cold weather standard after FERC on June 27 accepted EOP-012-2 (Extreme cold weather preparedness and operations) while ordering additional “targeted modifications” to be completed by next March (RD24-5). 

The approval of EOP-012-2 brings to an end what FERC Chair Willie Phillips called the “second round on this particular standard” at the commission’s monthly open meeting. Phillips commended NERC for its efforts to improve the grid’s resilience to cold weather impacts while observing that there is still a lot of work left to achieve the goals in the commission’s cold weather preparedness dashboard. 

“The standard … has helped close some ongoing reliability gaps and address many of the outstanding commission recommendations on winterization,” Phillips said. “Nevertheless, I would be remiss not to note that there are still changes that need to be made to help the standard reach its full potential.” 

NERC’s Board of Trustees approved EOP-012-2 in February. The standard’s 12-month development period began after FERC accepted its predecessor EOP-012-1 last year. 

The first version, which has yet to take effect, outlined several measures for generator owners to implement to prevent their units from freezing during extreme cold weather events, along with situations in which GOs would need to submit corrective action plans. However, FERC said the standard should be further revised to clarify language and enhance some of its requirements. 

EOP-012-2 underwent three formal comment and ballot periods before finally receiving the blessing of industry in January. (See Industry Approves New Cold Weather Standard in Final Vote.) NERC’s Board of Trustees had warned that it might have to step in to approve the standard if it looked like the ERO might miss FERC’s deadline — an authority it possesses under section 321 of NERC’s Rules of Procedure — but the successful ballot averted this possibility. 

FERC called the new standard an “improvement” to EOP-012-1 but said “some elements … are not fully responsive to the commission’s February 2023 order.” While it did not agree with the ISO/RTO Council’s request to remand EOP-012-2 to NERC for further revisions — which FERC observed would leave EOP-012-1 to go into effect Oct. 1 “despite its ambiguities and other identified issues” — the commission did identify some remaining shortcomings that still need to be overcome. 

FERC’s order directs NERC to submit another revised standard within nine months that: 

• • ensures that the standard’s generator cold weather constraint declaration criteria “are objective and sufficiently detailed” so that entities understand the requirements. NERC is to remove phrases such as “reasonable [or] unreasonable costs” and “good business practices” in favor of “objective, unambiguous and auditable terms.” 
  • allows NERC to evaluate and confirm the validity of cold weather constraints invoked by generator owners “to ensure that such declaration cannot be used to avoid” compliance with the standard or corrective action plans. 
  • shortens and clarify implementation timelines and deadlines for corrective action plans. 
  • ensures that any extension of a corrective action plan deadline beyond the maximum time frame provided by the standard is preapproved by NERC, and that GOs inform relevant entities of resulting extreme cold weather operating limits. 
  • implements more frequent reviews of generator cold weather constraint declarations to ensure the declaration is still valid. 

Noting the urgency FERC has “repeatedly expressed” for implementing cold weather standards, and the fact that the above directives are meant to “fully address issues identified in the commission’s prior February 2023 order,” FERC mandated that the ERO complete revisions to the standard within nine months. 

In a statement, NERC said it “appreciates FERC’s focus on reliability matters and will continue to work toward assuring the reliability and security” of the electric grid.