NERC Targets Cold Weather Performance

On September 18, 2025, the Federal Energy Regulatory Commission (FERC) approved EOP-012-3, NERC’s updated Extreme Cold Weather Reliability standard. This new standard strengthens generator cold weather preparedness requirements and improves the process for declaring Generator Cold Weather Constraints. These enhancements aim to ensure more reliable power generation during extreme cold weather events. 

Background 

When approving the previous version, EOP-012-2, FERC required NERC to revise the standard within nine months to address several key issues: 

• Clarify the definition of Generator Cold Weather Constraint. 
• Ensure NERC validates all Constraint declarations through a review and approval process. 
• Shorten and clarify timelines for implementing corrective action plans under Requirement R7. 
• Require NERC pre-approval for any extensions beyond the allowed implementation period. 
• Mandate more frequent reviews to confirm ongoing validity of Constraint declarations. 

Key Updates in EOP-012-3 

TRC clients should note that EOP-012-3 contains nine requirements and one attachment.  Requirements R1 through R8 have been carried over and modified from the prior version of the Standard, while Requirement R9 and Attachment 1 are new. 

Additionally, NERC has revised the definition of Generator Cold Weather Constraint in the NERC Glossary. Previously, generator owners were able to decline implementing certain freeze protection measures on existing or new equipment as part of correction action plans. While this option remains in EOP-012-3, NERC has clarified its proposed modifications by removing references to “cost,” “reasonable cost,” “unreasonable cost” and “good business practices.” 

Key Actions Required of Generator Owners 

To ensure compliance and readiness, Generator Owners should: 

• Review the FERC’s EOP-012-3 Order and the final standard. 
• Review internal compliance controls designed to assure compliance and identify changes needed considering the changes to the standard. 
• Assess their generating facilities for cold weather performance capability in accordance with the revised standard. 
• Submit accurate status of expected cold weather performance to the applicable reliability coordinator.
• Stay informed regarding evolving standards and participate in NERC webinars and outreach.