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Regulatory Updates

FERC Approves Modifications to NERC’s Cold Weather-Related Standards

Steve Persutti | September 7, 2021

The Federal Energy Regulatory Commission (FERC) has approved changes to three mandatory NERC Reliability Standards that aim to better prepare the North American power system to withstand extreme cold weather events. All utilities, even those not impacted by recent events, will be required to comply.

The modified standards include:

  • EOP-011-2 (Emergency Preparedness and Operations)
  • IRO-010-4 (Reliability Coordinator Data Specification and Collection)
  • TOP-003-5 (Operational Reliability Data)

NERC proposed the standards modifications in response to the findings of the NERC FERC Joint Report on the 2018 South Central Cold Weather Event. The changes address the need to winterize facilities; ensure the accurate reporting of design specifications to reliability coordinators for generating units; and the need for balancing authorities and reliability coordinators to be aware of, and plan for, generating units’ limitations during extreme cold weather.

Implementation Plan Approved

FERC also approved NERC’s proposed implementation plan for these changes with an effective date of April 1, 2023. This implementation plan was deemed reasonable by FERC because it accommodates those utilities that may need time to perform various engineering analysis; provide the required training; and develop the necessary capabilities to satisfy revised cold weather-related data specifications. FERC strongly encourages utilities that can comply with the new requirements of the three standards that were modified to do so before the effective date.

FERC also encouraged NERC to pursue the measures it described in its petition to support reliability during the upcoming winter 2021-22 season and any future winter season that occurs before the three standards modified to incorporate cold weather requirements become enforceable. On August 18, 2021, NERC issued a Level 2 Alert regarding Cold Weather Preparations for Extreme Weather Events under its NERC Alert process. The Alert calls for NERC registered entities to acknowledge receipt of the cold weathers advisory within the NERC Alert System, and report to NERC on the status of their activities in relation to the recommendations in the Alert.

Do Not Wait to Implement Compliance Measures

Notwithstanding the 18-month lead time in the approved  implementation plan and considering  FERC’s encouragement to comply earlier, it is critically important to assess whether your organization, its internal controls  and its facilities are prepared to meet the demands of expected winter weather across your service area. An independent examination of your internal controls relative to compliance is warranted prior to your next NERC compliance audit.

Whether your company was directly impacted by the recent cold weather-related system disturbance events or not, you will be obligated to comply with the FERC approved mandatory standards changes.

Next Steps

If due to recent experience your company is planning a proactive cold weather hardening program, TRC can help. Our technical 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 extreme cold weather in the future.

TRC offers extensive capabilities in generation related cold weather hardening plant retrofits, planning studies for extreme system events, and hardening substation equipment to perform during cold weather. We can support you with an independent review of your power generation and power delivery facilities to provide guidance regarding cold weather hardening and internal controls for compliance verification during your next audit.


Your Trusted Regulatory Advisor

TRC closely follows the national and state regulatory trends in all regions of North America. Our approach to power system planning, design and operations balances solutions that incorporate appropriate industry trends, mandatory standard requirements, regulatory guidance, compliance obligations, best practices, operational goals and budgets. With expertise in both power system planning and operations, we support public utilities and private energy providers to stay ahead of the curve on regulatory trends and the technical aspects of their operations, including related state and federal 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 reliability 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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