The Standards Authorization Request (SAR) related to cold weather grid operations submitted October 6, encompasses revisions to existing standards and the creation of new ones. While state entities like the Texas Public Utility Commission have taken immediate steps to require generators and transmission service providers to formulate plans for reliable cold weather operations, this SAR begins the process of including cold weather operations reliability in the NERC standards.

Download the NERC SAR

The SAR includes nine recommendations summarized below along with their implementation timeline.

• Generator Owners are to identify and protect cold-weather-critical components and systems for each generating unit. (Implementation Timeframe before Winter 2023/2024)
• Generator Owners are to design new or retrofit existing generating units to operate to a specified ambient temperature and weather conditions (e.g., wind, freezing precipitation). (Implementation Timeframe before Winter 2023/2024)
• Generator Owners and Generator Operators are to conduct annual unit-specific cold weather preparedness plan training. (Implementation Timeframe before Winter 2023/2024)

• Generator Owners that experience outages, failures to start, or derates due to freezing are to review the generating unit’s outage, failure to start, or derate and develop and implement a corrective action plan for the identified equipment, and evaluate whether the plan applies to similar equipment for its other generating units. (Implementation Timeframe before Winter 2022/2023).
• The Reliability Standards should be revised to provide greater specificity about the relative roles of the Generator Owners, Generator Operators and Balancing Authorities in determining the generating unit capacity that can be relied upon during “local forecasted cold weather,” which is language from the revised Reliability Standard TOP-003-5, R2.3. (Implementation Timeframe before Winter 2022/2023).
• In EOP-011-2, R7.3.2, Generator Owners are to account for the effects of precipitation and accelerated cooling effect of wind when providing temperature data. (Implementation Timeframe before Winter 2022/2023).
• To protect critical natural gas infrastructure from manual and automatic load shedding to avoid adversely affecting bulk power system reliability, Balancing Authority and Transmission Operator provisions for operator-controlled manual load shedding are to include processes for identifying and protecting critical natural gas infrastructure loads in their respective areas from firm load shed. (Implementation Timeframe before Winter 2023/2024).
• Balancing Authorities’ operating plans (for contingency reserves and to mitigate capacity and energy emergencies) are to prohibit use of critical natural gas infrastructure loads for demand response. (Implementation Timeframe before Winter 2022/2023).
• In minimizing the overlap of manual and automatic load shed, load shed procedures of Transmission Operators, Transmission Owners and Distribution Providers should separate the circuits that will be used for manual load shed from circuits used for underfrequency load shed (UFLS), undervoltage load shed (UVLS) or serving critical load. (Implementation Timeframe before Winter 2023/2024).

If you have ever considered monitoring the standards development process for issues directly related to how you plan, operate, and maintain your piece of the grid, now would be the time. This SAR will have near and long-term effects that will touch budgets, staffing, and training for years to come. As we have stated here several times, this process is incredibly transparent. All the details of any new or revised standard will be posted, opinions and reviews will be solicited, and responses to those opinions and reviews will be posted.

It’s also worth noting the section of the SAR that addresses the Cost Impact Assessment is “unknown.”

We will do our best here to monitor and provide insight on this SAR as it moves forward, but you know the specifics of your equipment and systems better than anyone. Make sure your potentially unique issues are addressed.