AUSTIN, Texas — Somewhat unnoticed among the plethora of organizations and associations related to the electric utility industry sits the North American Generator Forum, an independent, member-driven organization designed to provide a “united voice” on reliability, resiliency and security to NERC. 

During NAGF’s compliance conference and its annual meeting Nov. 6-7 at the Texas Reliability Entity’s headquarters, attendees shared their lessons learned and best practices with their peers. NERC staffers also called in with the latest developments at the agency. 

The NAGF is modeled after the larger North American Transmission Forum. It relies on its more than 80 member companies, accounting for about 53% of the bulk electric system’s capacity in North America, to share information in providing that “unified voice.” 

“We look to the Transmission Forum as kind of our guiding light,” Occidental Energy Ventures’ Venona Greaff, NAGF’s secretary, told ERO Insider. “We’re similar, but we’re quite a bit different because they have a full-time staff. We don’t. We do a lot of our efforts through the membership and through the volunteer efforts.” 

The NAGF’s generators provide their comments through the forum’s seven working groups. They include cold-weather preparedness, cybersecurity practices and variable resources. 

“They’re the experts specific to the standards that are applicable to that area,” said Greaff, a 30-year industry veteran who, in her day job, manages the NERC compliance program for Occidental Energy’s cogeneration fleet. 

“It’s sharing information, both among member to member but also getting information from the outside,” she added. “The whole purpose is just to assist our members … to help the generator community in general with compliance responsibilities, reporting responsibilities, understanding of standards and knowing what’s coming down the pipeline toward them.” 

Greaff and ERCOT’s David Kezell, director of weatherization and inspection, updated attendees at the annual meeting on revisions to NERC’s cold-weather standard (EOP-012-2, Extreme Cold Weather Preparedness and Operations). FERC accepted EOP-012-1 in 2023 but ordered revisions to be completed by 2024. That resulted in EOP-012-2, which the commission accepted in June while ordering that seven more changes be completed by March 2025. (See FERC Orders Further Cold Weather Standard Modifications.) 

The drafting team, which includes Greaff and several other NAGF members, has gathered feedback from the industry, asking for specific suggestions to strengthen the standard. Kezell, who chairs the team, said he expects only one more ballot will be posted from the three that are scheduled. The ballot will be live in December, setting up the NERC Board of Trustees’ consideration of the standard in March. 

To speed things along and meet FERC’s deadline, the team is using a shortened comment and ballot period of 20 days, rather than the usual 45 days. 

“We’ve been trying to approach this expeditiously. It’s an accelerated effort,” Kezell said. “We’re hoping to be able to take the responses that we got and the comments that we’ve received from this initial ballot and put together something that would be acceptable and we could get the requisite number of yes votes on the next round.” 

He said the biggest obstacle is coming up with an “appropriate” definition for generator cold weather constraints. The definition has been simplified to “any condition that would preclude a generator owner from implementing freeze protection measures on one or more generator cold weather critical components.” 

The team created a new attachment that establishes “highly common circumstances that would be appropriate for close to a blanket constraint that would be easily approved by the ERO,” Greaff said. 

“We called those pre-approved generator cold-weather constraints,” she said. “Ultimately, we may change that language, but the idea was to create a short list of things that we thought would be appropriately applied nearly everywhere.” 

The team also listed criteria describing a constraint and included them in the review. 

“We want to provide significant clarity to both the generator operators and to the regulatory personnel on what constitutes a valid generator cold-weather constraint,” Greaff said. 

There’s more to come. 

NERC is holding a technical conference on the cold-weather standard Nov. 12 at ERCOT’s headquarters. Speakers will review the FERC order, discuss the defined generator cold-weather constraints and share best practices. 

“As generators, it’s our chance to speak with the regulators, to hear where the constraints lie, but also to share thoughts with the drafting team so that we can move forward with the best approach in revising EOP 12,” Greaff said, encouraging her listeners to attend.