NERC Cold Weather Preparedness Standards UpdateApril 2024

On February 16, 2024, the North American Electric Reliability Corporation (NERC) submitted three cold weather operations and preparedness reliability Standards to the Federal Energy Regulatory Commission (FERC) for approval including EOP-011-4 (Emergency Operations), TOP-002-5 (Operations Planning), and EOP-012-2 (Extreme Cold Weather Preparedness and Operations). On February 22, 2024 FERC approved both EOP- 011-4 and TOP-002-5 which address actions taken by the Balancing Authority, Reliability Coordinator, and Transmission Operator during both Cold weather conditions and Extreme weather conditions. Both newly approved Standards will become effective October 1, 2024. As indicated in the updated timeline of the Cold Weather Standards development process, entities are expected to be ready to meet these new requirements per the implementation timelines for each Standard.

The new EOP-011-4 Standard requires entities to develop and implement Operating procedures to be utilized during cold or extreme weather events. The Standard added provisions for identification and prioritization of designated critical natural gas infrastructure loads, and for the identification of Distribution Providers, UFLS-Only Distribution Providers and Transmission Owners required to mitigate operating Emergencies in its Transmission Operator Area.

The new TOP-002-5 Standard requires Balancing Authorities to have extreme cold weather Operating Process(es) for its Balancing Authority Area addressing preparations for and operations during extreme cold weather periods that includes but is not limited to the identification of an extreme cold weather event, determination of adequate reserve margin during extreme cold weather, and a 5-day hourly forecast during an identified extreme cold weather period.

FERC has yet to approve the highly anticipated NERC proposed “Extreme Cold Weather Preparedness and Operations” Standard EOP-012-2. After NERC’s February 16, 2024 submittal, FERC received push back from industry grid Operator’s stating that the new standard sets “a low winterization bar” and includes “inappropriate exceptions” that will hinder the grid reliability during extreme weather events. One primary concern noted of NERC’s proposal is its allowance of power plant owners to declare a “Generator Cold Weather Constraint” that excuses them from putting in place freeze protection measures if the measures “could not have been implemented at a reasonable cost consistent with good business practices, reliability, or safety. A cost may be deemed unreasonable when implementation of selected freeze protection measure(s) are uneconomical to the extent that they would require prohibitively expensive modifications or significant expenditures on equipment with minimal remaining life”. The concern identified is that constraint declarations based on claims of unreasonable costs will be difficult or impossible to audit effectively and consistently. Another key concern is the issues associated with cost recovery of the Generator Owners required system improvements due to the new Standard in the wholesale power markets.

The February 2024 NERC filed EOP-012-2 Standard is applicable to Generator Owners and Generator Operators. Said proposed EOP-012-2 Standard has updated requirements and newly defined term(s) to be utilized by industry. These definitions include Generator Cold Weather Critical Component, Fixed Fuel Supply Component, Generator Cold Weather Reliability Event, and Generator Cold Weather Constraint. The Standard has redefined the applicable Facilities that are required to adhere to the requirements of the Standard. EOP-012-2 requires applicable Entities to Calculate Extreme Cold Weather Temperatures once every 5 calendar years (R1); Implement Freeze Protection if Extreme Cold Weather Temperature < 32 degrees Fahrenheit, and GO self-commits or is required to operate at or below a temperature of 32 degrees Fahrenheit (R2 / R3); Develop, implement, and maintain one or more cold weather preparedness plan (R4); Identify entity responsible for developing, assigning and providing generator specific cold weather training (R5); For a Cold Weather Reliability Event <= 150 calendar days, or July 1, review all events and develop Corrective Action Plans (CAPs) (R6); Implement, update, document CAPs within 24 calendar months of developing Plan, actions which require new equipment or freeze protection measures within 48 calendar months, and if not taking action document determination (R7); and For identified Cold Weather Constraint declarations – perform annual review and update declaration and/or operating limitations, as necessary (R8).

As stated by FERC, “while we successfully navigated the winter storms that occurred several weeks ago, it also underscores the ongoing need for vigilance and continued improvement in our preparations for extreme weather events.” “It is no secret that recent weather challenges have put the reliability of the grid to the test”. Since the 2021 Winter Storm Uri, both FERC and NERC have asked all affected entities to voluntarily implement the updated requirements as quickly as possible. In its guidance documents, checklists, and survey questions, NERC and its Regional Reliability Organizations (RROs) have indicated the importance of continuously reviewing, enhancing, and training on the Cold Weather Plan(s) utilized during the winter season. While not stated specifically in the newly proposed Standards, these reference documents represent NERC’s expectations of the information to be documented by each entity being audited. This includes development of a full cold weather operational plan to include all aspects of a strong emergency response plan, work instructions, training, annual management and inspections, critical component lists, cold weather lessons learned, Plan activation, readiness checks, and winter season readiness sign offs.

These Plans are essential in the successful operation of the electric grid during the cold weather season and should be utilized to take a proactive approach to prepare for, mitigate against, and respond to, Extreme Cold Weather Events that could impact the grid’s Generation Facilities. Reading the NERC Standards and Industry Guidance documentation it is apparent that Industry is expected to treat cold weather preparedness as an on-going, yearlong approach.

As with traditional business continuity plan designed to verify the capability of an organization to continue to deliver its services at pre-defined acceptable levels following a disruptive incident, the cold weather plan should also account for the primary phases of a strong plan including Planning/Preparing, Doing/Responding, Acting/Recovering, and Checking/Mitigating. Where the “Planning/Preparing” phase is the continuous cycle of planning, organizing, training, equipping, exercising, evaluating, and identifying improvement activities that ensure effective coordination and capabilities to prevent, protect against, respond to, recover from, and mitigate against cold weather events. Prior to and during a cold weather event, the “Doing/Responding” phase includes activation of this plan with the objective of ensuring personal safety and supporting system reliability. During the “Acting/Recovering” phase, an Entity’s aim is twofold, first to restore all affected equipment to its previous operational state, and second, to gather lessons learned from each event. These lessons learned are then utilized to evaluate the effectiveness of the cold weather program, identify areas of improvement, and enhance an Entity’s ability to reliably operate during, and minimize the risks prior to, the next Extreme Cold Weather Event. The “Checking/Mitigation” phase focus is to prevent or minimize impacts to operations and safety during cold weather events through lessons learned and corrective actions taken including plan enhancements and updates.

To assist Entities prepare for and comply with these new requirements, Archer has developed a Generator Owner / Generator Operator Cold Weather Preparedness package that aligns with the current NERC Cold Weather Requirements and industry guidance documentation. This easily customizable package includes templates for the preparedness plan, RSAW development, training on the Cold Weather Standards and NERC expectations, along with worksheets, tables, and forms designed specifically to meet the various requirement activities of the Standards such as training, annual maintenance, inspections checklists, Corrective Action Plans, and NERC survey questionnaires. The package is designed to provide entities with a one stop shop to not only prepare for and meet the new cold weather Standards but to also increase its ability to reliably serve its systems during extreme weather events in a sustainable manner that is easily auditable.

Please feel free to ask Archer to assist you in any of your Cold Weather Standard needs. We have a team of experts ready to customize your Plans and/or train your team on what is required and empower them to implement the Plan themselves. Please contact Catrina Martin at or (801) 903-3102.

We look forward to working with you in the future!