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Regulatory Updates

Cold Weather Reliability Preparedness and Hardening

Steve Persutti | March 22, 2021

Much is currently being written about the impact of recent cold weather events on power systems in the US. As government investigations move toward conclusions there will inevitably be recommendations for mandatory regulatory change.

The good news is that operator intervention saved the impacted power systems, but the bad news is that those systems (both generation and delivery) were proven to not be robust enough to withstand extreme weather.

While both NERC and FERC have been examining and identifying this issue over the last few years, the latest weather impacts to reliability have accelerated the need for the compliance changes that are likely to occur. Utilities will need to stay ahead of regulatory developments and make the needed system or facility upgrades.

Background: NERC Cold Weather-Related Standards Revisions

In July 2019, the Federal Energy Regulatory Commission (FERC) and NERC staff released a report titled The South-Central United States Cold Weather Bulk Electric System Event of January 17, 2018. Among the takeaways, given prior experience with voluntary guidelines, was a firm recommendation to develop either a new standard or modifications to existing standards to address cold weather preparation.

The NERC standards development project 2019-06 drafting team reviewed the lessons learned from prior events and has begun to address cold weather readiness and performance. The proposed standards revisions call for cold weather operating plans and focus on generating unit-specific design specification or required minimum historical performance demonstrations during cold weather. There will be new obligations for asset owners to identify the expected BES generating unit operation limitations during locally forecasted cold weather.

Changes Will Be Forthcoming: Stay Ahead of the Regulatory Curve

FERC and NERC have announced that they will open a joint inquiry into the operations of the bulk power system during the February 2021 extreme winter weather conditions in the Midwest and South-Central states. It is highly likely that power system design considerations will be changing. Staying ahead of new requirements -and continuing to comply with existing guidelines- is critical to operational success and preserving reliability for your customers.

It is important to assess whether your organization is properly focused on meeting the demands of winter weather, with adequate winter transmission line and substation equipment ratings. An independent examination of your company’s FAC-008 ratings methodology is probably warranted and is a good place to start considering the cold weather event performance.

Another area of focus in the winter is facility mechanical loading. You will need to review your structural designs and take into consideration the potential for more severe ice loading than your company may be currently assuming. Additionally, the impact of extremely low temperature on gas insulated buss work and switchgear can impact potential cold weather preparedness. You should expect related requirements to be modified in the future.

Whether your company was directly impacted by recent events or not, it is clear your company will be impacted by the mandatory standards changes that are coming. The lead time to identify cold weather weaknesses and to make changes could be significant.

Next Steps: TRC Can Help

If due to recent experience your company is planning a proactive cold weather hardening program, TRC can help. Our teams have expertise in all power generation and power delivery engineering subject areas. We can provide an independent review of your current equipment situation and assess its ability to perform as designed during cold weather, helping you meet requirements to commit to certain performance expectations during cold weather in the future.

TRC offers extensive capability in generation related cold weather hardening plant retrofits, planning studies for extreme system events, hardening substations against cold weather. We can support you with an independent review of you power generation and delivery facilities to provide guidance regarding cold weather hardening.


About TRC

TRC’s approach to power system planning, design and operations balances solutions that incorporate appropriate standards, regulatory requirements, compliance obligations, best practices, operational goals and budgets. Our work for public and private sector clients is a testament to our understanding of power system operations and planning and our successful application of technological solutions in a constantly evolving business and regulatory landscape.  TRC advises numerous utilities on how to stay ahead of the curve regarding the technical aspects of their mandatory compliance obligations.

This regulatory update is a service to TRC’s utility clients, helping keep you informed of issues that impact your company’s electric system security risks along with related topics regarding regulatory developments to help you achieve your company’s business goals.

Steve Persutti

Steve Persutti is TRC’s Senior Vice President of Business Development. He has 25 years of comprehensive management experience within the energy industry and a consistent and successful record in strategic business planning, productivity and efficiency improvements, systems design and implementation, and employee collaboration. His areas of expertise include engineering management, project management, EPC project management, construction management, financial analysis and customer service. Steve has an M.B.A in Finance from the University of Hartford and a B.S. in Marketing from the University of Connecticut. Contact Steve at

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