Project-2024-03-Revisions-to-EOP-012-2

 

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Status
A formal comment period for draft two of EOP-012-3 Extreme Cold Weather Preparedness and Operations is open through 8 p.m. Eastern, Friday, December 20, 2024​.​ 

Additional ballots for the standard and implementation plan, as well as a non-binding poll of the associated Violation Risk Factors and Violation Severity Levels will be conducted December 16 – 20, 2024.

The Standards Committee approved the following waiver of provisions of the Standard Processes Manual (SPM) for Project 2024-03 Revisions to EOP-012-2:​​​​​​

• Informal comment period for SAR reduced from 30 days to as few as 15 days (Section 4.2);
• Initial formal comment and ballot period(s) reduced from 45 days to as little as 20 days, with the ballot pool formed concurrently during the first 10 days of the initial formal comment period, and with the ballot and non-binding poll of Violation Risk Factors (VRFs) and Violation Severity Levels (VSLs) conducted concurrently during the last 5 days of the comment period (Sections 4.8 and 4.9);
• Additional formal comment and ballot period(s) reduced from 30 days to as little as 15 days, with the ballot and non-binding poll of VRFs and VSLs conducted concurrently during the last 5 days of the comment period (Sections 4.9 and 4.12);
• Final ballot period(s) reduced from 10 days to as little as 5 days (Section 4.13).
  

Background
​NERC developed the original version of the generator cold weather preparedness Reliability Standard, Reliability Standard EOP-012-1, in 2022 under Project 2021-07 Extreme Cold Weather Grid Operations, Preparedness, and Coordination. The purpose of this project was to address standards-related recommendations from the Federal Energy Regulatory Commission (FERC)/NERC/Regional Entity staff review of operations during the February 2021 Winter Storm Uri event.

NERC developed Reliability Standard EOP-012-2 in 2023-2024 to address Commission directives from the February 2023 order approving Reliability Standards EOP-012-1 and EOP-011-3. In the February 2023 Order, the Commission directed that NERC revise EOP-012-1 to clarify the applicability of the standard's requirements for generator cold weather preparedness, further define the circumstances under which a Generator Owner may declare that constraints preclude them from implementing one or more corrective actions to address freezing issues, and to shorten the implementation timeline so cold weather reliability risks would be addressed more quickly.

On June 27, 2024, FERC issued an order approving Reliability Standard EOP-012-2. While finding Reliability Standard EOP-012-2 represented an improvement over the prior version and addressed many of its concerns, FERC found the standard requires further improvement to address certain concerns remaining from its February 2023 order. FERC therefore directed NERC to revise the standard in five areas and to submit a revised standard within nine (9) months of the date of the order, or by March 27, 2025.  

Standard Affected: EOP-012-2

Purpose/Industry Need
The purpose of this project is to address the directives identified by FERC in its June 27, 2024 order approving Reliability Standard EOP-012-2 and directing further modifications. N. Am. Elec. Reliability Corp., 187 FERC ¶ 61,204 (2024), available here. In that order, FERC found that further improvements needed to be made to address ambiguous language and address other reliability gaps/implementation issues in the standard and related definitions to fully address issues first raised in the Commission's February 2023 Order approving EOP-012-1. FERC directed that NERC submit the modifications within 9 months of the date of the order, or by March 27, 2025.

Proposed Project Timeline 
The project timeline is listed below for industry awareness. This table will be updated with any changes as the project progresses.​​