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Regulatory Updates

NERC Proposes Clarifications to EOP Cold Weather Standards

Dylan Achey, Dwayne Stradford | March 22, 2024

NERC has submitted proposed revisions to the EOP-012-2 – Extreme Cold Weather Preparedness and Operations standard, for FERC approval on an expedited basis.

The proposed revisions address the remaining key recommendations from the FERC–NERC Joint Inquiry Report into Winter Storm Uri and directives arising from a 2023 FERC Order regarding the previously submitted cold weather standards. The revised standard requires Generator Operators to develop more comprehensive cold weather preparedness plans than originally called for in EOP-012-1 and ensures that generator personnel complete training annually.

In its filing with FERC, NERC noted that the proposed EOP-012-2 standard improves upon EOP-012-1 and clarifies the applicability of requirements for generator cold weather preparedness and defines how a Generator Owner may declare when events prevent them from completing corrective actions to address freezing issues. The proposition also shortens the implementation timeline so that cold weather reliability risks would be addressed more quickly.

EOP-012-2 reflects additional improvements that address the recommendations of the FERC, NERC, and Regional Entity Staff Joint Inquiry into the causes of the February 2021 cold weather event impacting Texas and the south-central United States.

NERC is seeking FERC’s expedited approval of EOP-012-2 in light of the pending Reliability Standard EOP-012-1 which becomes effective October 1, 2024.

Standard Modifications and Clarifications

The filed EOP-012-2 standard improvements relative to EOP-012-1 include:

  • Clarifying the applicability of the standard, so all Generator Owners continue to be required to develop cold weather preparedness plans and train on those plans consistent with currently effective EOP-011-2;
  • Clarifying the limited exemption for the EOP-012 winterization requirements, so that it is clear the only units that would be exempted from applying freeze protection measures are those Bulk Electric System units that do not operate in freezing conditions (except in a limited capacity, during an Emergency);
  • Clarifying that the standard would apply to new intermittent energy resources, and that they must provide capability to operate for their maximum operational duration if that is less than 12 hours (e.g., solar farm in area with less than 12 hours of sunlight in winter);
  • Clarifying the limited circumstances under which a Generator Owner could declare constraints preventing them from implementing a specific corrective action contained in a Corrective Action Plan to address freeze protection issues;
  • Clarifying the steps Generator Owners would take when they declare a constraint, including reporting any reliability-related impacts to reliability entities as part of their generating unit cold weather data;
  • Adding deadlines for actions in a Corrective Action Plan;
  • Abbreviating the overall timeline for implementation of the EOP-012-2 standard, so that reliability risks would be addressed more quickly.

As TRC clients prepare their NERC cold weather-related compliance plans, given the changing compliance requirements related to their current EOP-012-1 preparations, we strongly advise planning for an implementing proactive compliance adaptations.

FERC Approval is Pending

The FERC Chair recently made a public statement related to the approval of other cold weather standards where he urged the industry to achieve compliance before the mandated cold weather requirement effective dates wherever possible. Stakeholders should consider this regulatory “request” and adjust their compliance efforts accordingly.

TRC’s technical teams have the necessary expertise in all power generation and power delivery engineering practices to advise an independent review your company’s cold weather standards compliance effort. TRC can provide services to review your cold weather compliance program and offer an independent review of your current generation and delivery facilities’ cold weather capabilities. TRC is well positioned to assess your technical team’s ability to perform as required during cold weather to support compliance with the coming regulations. 

The timelines are accelerated, and the amount of work is significant. TRC can help your company meet the coming requirements in this area of focus by FERC, NERC, and the NERC Regions. TRC can assist with expediting your efforts in this high-profile area of reliability risk mitigation and NERC compliance.


NERC EOP-012-2 Filing

EOP-012-2 as filed

EOP-012-2 redline to prior EOP-012-1

EOP-012-2 Implementation Plan

NERC Compliance for Registered Generator Operators and Owners.pdf 

FERC & NERC Issue Joint Report on Freeze Reliability Failures

Update on NERC Acceleration of Additional Cold Weather Standards Changes

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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