The North American bulk power system cannot operate reliably without sufficient generation during extreme cold weather events, like what was experienced during Winter Storms Uri and Elliot in 2021 and 2022, respectively. NERC Reliability Standard EOP-012 serves to mitigate cold weather generator risk. On June 27, 2024, the Federal Energy Regulatory Commission (FERC) approved the version EOP-012-2 of the standard, which addresses Extreme Cold Weather Preparedness and Operations. While EOP-012-2 was approved, FERC directed NERC to make several improvements within nine months of the date of the order, or by March 27, 2025.
A key modification outlined in FERC Order 187 FERC ¶ 61,204 focuses on the need to clarify the newly introduced term “Generator Cold Weather Constraint.” The current definition includes criteria such as the inability to implement a freeze protection measure at a reasonable cost. Under the current language, a cost may be deemed “unreasonable” if the required modifications are prohibitively expensive or involve equipment nearing the end of its operational life.
FERC’s Directive for Objective and Auditable Criteria
FERC expressed concerns about the subjective nature of the “Generator Cold Weather Constraint” declaration criteria. For clarity and consistency, FERC directed that all references to terms like “reasonable cost,” “unreasonable cost,” “cost,” and “good business practices” be replaced with objective, unambiguous, and auditable language in the next version of the standard. The goal is to provide entities with clear compliance obligations and reduce risks to the bulk power system during extreme cold weather events.
ERO Enterprise Prepares Area of Concern (AOC) During Engagements
In response to FERC’s directive, the ERO Enterprise plans to issue an AOC for any Generator Cold Weather Constraint declaration that relies on subjective justifications, such as “reasonable cost” or “good business practices,” to avoid implementing actions outlined in a Corrective Action Plan. The AOC will also apply to other similar terms identified by FERC for removal.
An AOC is issued by the ERO Enterprise when an issue, if not addressed, could develop into future noncompliance or risk to the bulk power system. Ineffective or nonexistent internal controls may contribute to an area of concern.
The ERO Enterprise will provide AOCs for this issue until the effective date of the next version of the standard, EOP-012-3, when it is approved.
Next Steps for Compliance
NERC registered entities are encouraged to follow the development of the EOP-012-3 standard through the “Project 2024-03 Revisions to EOP-012-2” page. Generator Owners should begin reviewing current Corrective Action Plans and internal processes to ensure that Generator Cold Weather Constraint declarations align with FERC’s directive.
By proactively addressing these changes, Generator Owners may mitigate risk to the bulk power system and support adherence to the evolving reliability standards.
– Sam Zewdie, MRO Principal Compliance Engineer