Good morning, Chairman and Commissioners,
Recent extreme cold weather events across large portions of North America have shown the importance of ensuring that the Bulk-Power System is prepared for extreme cold weather. In February 2021, Winter Storm Uri led to the largest controlled firm load shed event in U.S. history, with over 4.5 million people losing power and at least 210 people losing their lives during the event. Shortly thereafter, the Commission, along with NERC and Regional Entities, initiated a joint staff inquiry into Winter Storm Uri that resulted in the issuance of a joint report in November of 2021. The report included recommendations for Reliability Standard enhancements to improve extreme cold weather operations, preparedness, and coordination.
The draft order in item E-1 is a step towards addressing the ongoing risk posed by extreme cold weather events to the Bulk-Power System. The draft order would approve two NERC Reliability Standards, EOP-011-3 (Emergency Operations) and EOP-012-1 (Extreme Cold Weather Preparedness and Operations). The proposed Standards respond to several key recommendations from the joint inquiry report into Winter Storm Uri, and a NERC standards drafting team is continuing to work on additional, related recommendations from the joint report.
NERC’s proposed Reliability Standards contain new and revised requirements to advance system reliability by requiring generator owners to:
- implement freeze protection measures on their applicable generating units based on the extreme cold weather temperatures for their units’ locations, including enhanced cold weather preparedness plans;
- identify generator cold weather critical components that are susceptible to freezing;
- implement corrective actions to ensure that the identified causes of equipment freezing do not recur;
- design and implement annual training for generation maintenance and operations personnel; and
- develop procedures to improve the coordination of load reduction measures during a grid emergency.
The draft order also would find that new Reliability Standard EOP-012-1 needs improvement to address concerns relating to (1) the ambiguity of facility applicability, (2) generator-defined declarations of technical, commercial, or operational constraints that exempt a generator owner from implementing the appropriate freeze protection measures; (3) the 12 continuous hour requirement for new generating units under Requirement R1; (4) the one-hour continuous operations requirement for existing generating units under Requirement R2; (5) the extensive period before generators must implement freeze protection measures or develop corrective action plans; and (6) the lack of a time limit for completion of corrective action plans once they are developed. Thus, the draft order would direct NERC to modify Reliability Standard EOP-012-1 to clarify certain language, enhance certain Standard requirements, include criteria on permissible constraints, and identify the appropriate entity that would receive the generator owners’ constraint declarations under the Standard.
Lastly, to ensure that Reliability Standard EOP-012-1 is adequately addressing reliability concerns related to generator owner constraint declarations and the adequacy of the newly developed Extreme Cold Weather definition, the draft order would direct NERC to work with Commission staff to submit a plan no later than 12 months after the date of issuance of this order on how it will collect and assess data periodically to monitor the implementation of the new requirements for generator owners.
This concludes our presentation. We are happy to take any questions you may have.