In their last opportunity to provide feedback on NERC’s most recent proposed cold weather standard, several grid stakeholders continued to express doubt the standard will satisfy FERC’s directive to the ERO.

NERC’s Standards Committee approved EOP-012-3 (Extreme cold weather preparedness and operations) for a 45-day formal comment period at its meeting on Jan. 22. The actual comment period began Jan. 27 and ended March 12.

A formal ballot round normally would be conducted during the comment period, but will not take place in this case because the cold weather standard is the subject of a decision by NERC’s Board of Trustees to exercise its authority under Section 321 of the ERO’s Rules of Procedure. (See NERC Board Invokes Section 321 Authority for Cold Weather Standard.)

The board decided to take the Section 321 route after the standard failed its most recent formal ballot round that concluded Dec. 20 with only a 44.54% segment-weighted vote in favor, far short of the two-thirds majority required for passage. This represented an improvement of only about 2% from the previous ballot round, and the board worried that NERC might miss FERC’s deadline of March 27 to submit the new standard for commission approval.

After the comment period concludes, NERC will review all comments received, staff told the SC in January. (See Cold Weather Standard Set for Posting.) Trustees then will hold a special call ahead of FERC’s deadline to review the standard and any comments the committee considers relevant.

In its comment form, NERC asked stakeholders to respond to several questions based on elements of FERC’s order last year directing changes to EOP-012-2 (RD24-5). While most respondents said the new standard would satisfy the commission’s directive, the sentiment was far from unanimous.

Regarding the first question — which dealt with whether the standard’s generator cold weather constraint declaration criteria were “objective and sufficiently detailed” — Ruchi Shah, writing on behalf of AES U.S. Renewables, said he was “concerned the language used in several … criteria can be left to interpretation by the regional entities.”

Specifically, he said the phrase “comparable types in regions that experience similar winter climate conditions” lacked guidance as to how to interpret it.

Richard Vendetti of NextEra Energy similarly said while the newest revision added language regarding generator constraint criteria for wind turbines, there still were “many unknowns regarding specific criteria for solar generation.”  Without similar detail for solar generators, entities would not understand what is required of them, he said.

Vendetti also said “NextEra would like to see industry visibility on the approval and denial of cold weather constraints,” and that transparency from the ERO on this subject would show industry what type of constraints are likely to be approved and help utilities save time and resources.

Another inquiry concerned NERC’s question about timelines for implementing corrective action plans (CAPs) after generator cold weather reliability events. Representatives from ACES Power said while the latest draft represents an improvement over previous efforts, the proposed standard still is “too ambiguous and may unduly discriminate against” generator owners arbitrarily.

ACES’ writers used the example of two entities that experience cold weather events on Oct. 22, 2025, and March 16, 2026. Under the proposed EOP-012-3, ACES said, both entities would have until Dec. 1, 2026, to implement a CAP, which in practice gives one entity much greater time for its fix. The commenters suggested modifying the standard to allow 12 calendar months for CAP implementation regardless of when the cold weather event occurs.