The Standards Authorization Request (SAR) related to cold weather grid operations submitted October 6, 2021, began a series of technical document development, revisions to existing standards, and creation of new standards. 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. These recommendations have an implementation timeline before winter 2023/2024. Some recommendations were steered by NERC-issued technical documents or guides while some were included in updates to current or revised NERC Reliability Standards. Some will be included in new NERC Reliability Standards with corresponding revisions and retirements of the existing standards. While mainly targeted to Generator Owners, due to their knowledge of their generation systems, the changes also relate to processes performed by Transmission Operators and Balancing Authorities in their functions related to transmission system reliability.

The nine recommendations are summarized below with an update on current status:

• Generator Owners are to identify and protect cold weather-critical components and systems for each generating unit. (Implementation timeframe before winter 2023/2024)
  • Update: this essential action should be complete or nearing completion with the Winter 2023/2024 season approaching quickly. As of October 6, 2023, the Generator Owner should have calculated an Extreme Cold Weather Temperature (ECWT) for each of their applicable generators and identified any components impacted by that ECWT, in conjunction with NERC Alert: Essential Actions to Industry – Cold Weather Preparations for Extreme Weather Events III. The ECWT is used in the Cold Weather Preparedness plan required by EOP-011-2 Requirement R7. The final version of EOP-012-1 documents Generator Owner requirements related to the cold weather preparedness plan when it becomes effective on October 1, 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)
  • Update: this essential action should be complete or nearing completion for the upcoming winter 2023/2024 season. Currently, EOP-011-2 Requirement R7 provides the details required of the Generator Owner. These details are carried over and expanded upon in EOP-012-1, which will become effective on October 1, 2024.

• Generator Owners and Generator Operators are to conduct annual unit-specific cold weather preparedness plan training. (Implementation timeframe before winter 2023/2024)
  • Update: this essential action should be complete or nearing completion for the upcoming winter 2023/2024 season. This essential action has been incorporated into EOP-011-2 Requirement R8 and will be addressed in the future by EOP-012-1 Requirement R5 when it is effective on October 1, 2024.

• Generator Owners that experience outages, failures to start, or derates due to freezing are to review the incident and develop and implement a corrective action plan for the identified equipment. They also must evaluate whether the plan applies to similar equipment for their other generating units. (Implementation timeframe before winter 2022/2023)
  • Update: this essential action should be complete since the deadline was prior to last winter (2022/2023). While not specifically incorporated into EOP-011-2, the development of the corrective action plan is included in EOP-012-1 Requirements R2, R4, R6, and R7 when it is effective on October 1, 2024.

• 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 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)
  • Update: TOP-003-5 came into effect as of 4/1/2023.

• In EOP-011-2 R7.3.2, Generator Owners are to account for the effects of precipitation and accelerated wind cooling when providing temperature data. (Implementation timeframe before Winter 2022/2023)
  • Update: this essential action should be complete since the deadline was prior to last winter (2022/2023). While incorporated in EOP-011-2 as stated in the SAR, this essential action is more clearly detailed in EOP-011-2 Requirement R8 and will be addressed in the future by EOP-012-1 Requirement R3.3 when it is effective on October 1, 2024.

• To protect critical natural gas infrastructure from manual and automatic load shedding and 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)
  • Update: this essential action should be complete or nearing completion for the upcoming winter 2023/2024. Changes related to this essential action should be incorporated into the Balancing Authority’s and Transmission Operator’s processes and procedures associated with manual and automatic load shedding.

• 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)
  • Update: this essential action should be complete or nearing completion for the upcoming winter 2023/2024. Changes related to this essential action should be incorporated into the Balancing Authority’s operating plan processes.

• 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)
  • Update: proposed Reliability Standard EOP-011-3 is a revised Reliability Standard that addresses Recommendation 1j of the Report, minimizing the overlap of manual Load shed and automatic Load shed programs such as UFLS and UVLS. This revision also removes Requirements R7 and R8, as this language was moved to the new EOP-012-1.

Several Reliability Standards will be updated moving into this winter 2023/2024 season. 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 is the time. This SAR has had near- and long-term effects that will affect budgets, staffing, and training for years to come.

As we have said before, this process is completely 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 remains unknown.

We will continue to monitor and provide insight into 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.