By Laura Christensen, Senior NERC Reliability Specialist 

NERC, in accordance with its regulatory obligations under the Federal Power Act, has initiated a draft data request concerning the operation of generators during cold weather. The draft is in response to the Federal Energy Regulatory Commission (FERC) directive to develop a plan to collect data on the winterization of generating units. Comments can be made using the comment matrix. It will involve an annual filing for the analysis of cold weather data. The draft has a comment period until July 29, 2024. This initiative stems from past events where cold weather caused significant impacts on the Bulk Electric System (BES) generation, leading to firm load shed in several instances.  

In response to these directives and to fulfill its obligations, NERC has outlined a comprehensive approach. NERC and FERC have undertaken various activities such as developing Reliability Standards, issuing NERC Alerts, and reviewing generator performance during cold weather. Additionally, FERC directed NERC to develop a plan for collecting data on winterization efforts of generating units, including assessing their capability to perform under extreme cold conditions and reporting on the efficacy of freeze protection measures. In response, NERC submitted a work plan detailing its data collection and analysis strategy, with annual informational filings scheduled to commence from October 2025. NERC plans to use this data to support the implementation and monitoring of cold weather Reliability Standards, potentially revising data requests and leveraging existing systems like the Generating Availability Data System (GADS) for sustained data collection in the future. 

In establishing its authority to request data, NERC operates within a framework defined by federal legislation and regulatory mandates. This authority is rooted in Section 215 of the Federal Power Act, which grants FERC the oversight responsibility for ensuring the reliability of the Bulk-Power System (BPS) and designing an Electric Reliability Organization (ERO) tasked with developing and enforcing mandatory Reliability Standards. NERC, as the certified ERO, further delineates it authority under 18 C.F.R. §39.2(d): 

Each user, owner or operator of the Bulk-Power System within the United States (other than Alaska and Hawaii) shall provide the Commission, the Electric Reliability Organization and the applicable Regional Entity such information as is necessary to implement Section 215 of the Federal Power Act as determined by the Commission and set in the Rules of the Electric Reliability Organization and each applicable Regional Entity. The Electric Reliability Organization and each Regional Entity shall provide the Commission such information as it deems necessary to implement section 215 of the Federal Power Act. 

Rules of Procedure further detail procedures for requesting data, including public comment periods and Board of Trustees’ approval processes, ensuring compliance with reliability standards and confidentiality protocols. The rules of procedure found in Section 1600 as referenced below:  

• 1601. Scope of a NERC or Regional Entity Request for Data or Information 

• 1602. Procedure for Authorizing a NERC Request for Data or Information 

• 1603. Owners, Operators, and Users to Comply 

• 1605. Confidentiality. 

Data Handling and Need for Data outlines how data will be used by NERC and Regional Entities to meet obligations under applicable laws, specifically related to analyzing cold weather impacts on energy infrastructure. The data will focus on capacity impacts, constraints, outage risks, and cold weather preparedness. It will be collected annually from Generator Owners by April 15, starting from 2025, using a secure automated mechanism. Data will be treated as confidential and aggregated for public reporting to FERC, minimizing burden on Reporting Entities by leveraging existing data where possible. 

NERC will request Reporting Entities to submit the data using a secure automated data collection mechanism that NERC will develop. For ease of review, NERC is reproducing the questions below. 

1. GO-NCR #: For the Generator Owner (GO) functional registration only, please enter the company’s NERC Compliance Registry Number. 

2. GO Name: Please enter the name of the GO as found on the NERC Compliance Registry. 

3. Company GADS Identifier: Please enter the company’s 3-digit GADS Identifier number, 7-digit for 

4. conventional generators, 7-digit Plant ID for GADS Wind or GADS Solar plant). If the Generator Owner has units that do not report to GADS, use 000 as the GADS company identifier. 

For the following questions, Responding Entities will fill out a spreadsheet row for each BES generating unit owned by the GO. A plant with multiple units at a single location should have a single row for each unit. Some questions below refer to terms used in EOP-012. 

1. Unit GADS identifier (3 digits for conventional generators, 7-digit Plant ID for GADS Wind or GADS Solar group). If the Generator Owner has units that do not report to GADS, use 000 as the GADS unit identifier. 

2. Plant EIA Code (free text) 

3. Unit EIA Code (free text) 

4. Unit Postal Zip Code (5 digits) 

5. NERC Regional Entity where unit is located (3-4 char regional abbreviation used by NERC) 

6. NCR ID of BA for BA Area where unit is located 

7. Gen Unit Name 

8. Unit Extreme Cold Weather Temperature (ECWT) (deg F) 

9. Date ECWT calculated (mm/dd/yyyy) 

10. Minimum Operating Temp (deg F) 

11. Maximum Operating Temp (deg F) 

12. Total Net Winter Capacity (MW) 

13. Total Capacity Operable at ECWT (MW) 

14. Total Capacity with Corrective Action Plans (CAPs) developed (MW) 

15. CAP Development Date (mm/dd/yyyy) 

16. Projected CAP Completion Date (mm/dd/yyyy) 

17. Did the unit experience a Generator Cold Weather Reliability Event this winter? (Y/N) 

18. Is the unit under a CAP because it was identified as “similar equipment”? (Y/N) 

19. Description of the “similar equipment” identified (free narrative text) 

20. Unit has a Generator Cold Weather Constraint identified? (Y/N) 

21. Constraint Rationale (drop down menu) 

1. Commercial 

• Commercial – warranties would be voided by application of freeze protection measure 

• Commercial – cost is prohibitively expensive 

• Commercial – significant expense on equipment with minimal remaining life 

• Commercial – other (free text narrative; one sentence) 

2. Technical 

• Technical – technology not used by a significant portion of electric industry for similar units 

• Technical – no commercially viable solutions 

• Technical – other (free text narrative; one sentence) 

3. Environmental 

• Environmental – introduces unacceptable risk of noncompliance with environmental regulations on unit 

• Environmental – other (free text narrative; one sentence) 

4. Operational 

• Operational – accelerates retirement of existing unit 

• Operational – cancellation of new generating unit 

• Operational – reduces reliability of unit in warm weather or normal conditions 

• Operational – introduces increased personnel or safety risk 

• Operational – compromised ability to provide ancillary services 

• Operational – other (free text narrative; one sentence) 

• Other (free text narrative; one sentence)