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Regulatory Update

NERC & FERC Release Winter Storm Elliott Report

Dylan Achey and Dwayne Stradford | January 2, 2024

NERC and FERC have released their final report on Winter Storm Elliott which provides reinforcement for recommendations in prior cold weather-related disturbance event reports. The Report identifies critical reliability performance shortcomings and the reliability related near misses. NERC states that a crisis was “narrowly dodged.” The Report outlines the steps the industry must take to avoid a repeat in the future.

There are many far reaching, detailed recommendations in the Report for Regulatory Authorities, Owners and Operators of Electric Systems, Gas Systems and electricity Generators. The report contains a recommendation to establish a regulatory framework for reliability rules applicable to gas systems.

To address the reliability risks outlined in the Elliott Report, NERC released the results of its first issued Level 3 Essential Actions Alert for Cold Weather Preparations for Extreme Weather Events. The results of the Alert are provided to industry to inform and support cold weather state of readiness of the Generator Operators (GO), Transmission Operators (TOP), Balancing Authorities (BA), and Reliability Coordinators (RC). The purpose of this release is to help the industry enhance its plans for, and make accelerated progress toward, mitigating electric system reliability risk for Winter 2023-2024 and beyond.

Next Steps

To stay ahead of reliability risk issues and any additional FERC mandated compliance obligations, TRC recommends that your company reviews the Elliott Report and the Level 3 Alert Report to assess the implications of the recommendations for your respective company and its functions in the power system.


Winter Storm Elliott Report

NERC Findings from Level III Essential Actions for Cold Weather Preparations for Extreme Cold Weather Events Alert (


TRC Regulatory Update on NERC Cold Weather Standards

Your Trusted Regulatory Advisor

TRC closely follows the national, provincial, and state regulatory trends in all regions of North America. Our approach to power system security, engineering, planning, design, construction and commissioning testing, balances solutions that incorporate industry reliability risk trends, mandatory reliability standard requirements, regulatory guidance, compliance obligations, best practices, operational goals, and budgets. With expertise in power system planning, engineering, and operations, TRC supports public utilities and private energy providers in their efforts to stay ahead of the regulatory curve and to meet or exceed regulatory requirements as they evolve.

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

Dylan Achey

Dylan Achey is TRC’s Manager of Generation Engineering Services. He has been leading the effort with TRC generation clients on evaluating and providing updates/information so that clients can meet applicable NERC standards. His highly technical staff perform NERC compliance standard evaluations as well as studies for both generation and transmission clients that need assistance on technical issues concerning NERC compliance. Contact Dylan at

Dwayne Stradford

Dwayne Stradford serves as TRC’s NERC Compliance Director in the Power Division. He is leading and coordinating TRC’s NERC compliance support services with our various power utility clients. He is an accomplished, diverse energy professional with over 30 years of engineering experience regarding real-time transmission operations, short/long term transmission planning, NERC Reliability Compliance Standards (both NERC-CIP and NERC O&P), Transmission Reliability Assurance, utility scale renewables integration, FERC Regulatory/RTO policy, and Project Management. He spent the bulk of his career (close to two decades) working for AEP but has considerable working experience in the electric utility industry as a professional consultant. He has worked with utility clients on transmission and generation related projects in all three interconnections, so he has breadth of regional BES experience throughout the entire country. Please contact Dwayne Stradford for more information.

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