EOP-012 Cold Weather Preparedness
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By Laura Hankins
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On October 8, 2026, the NERC Board of Trustees adopted EOP-012-4, note that this standard is a proposed variance for Canadian entities only. The EOP-012-4 Technical Rationale provides additional details.
Lately, there has been a focus on the Extreme Cold Weather Temperature (ECWT) calculation and the associated guidance. Accurate Extreme Cold Weather Temperature (ECWT) calculations depend on appropriate data sets, reliable source data, and adjustments for missing or invalid data.
The Calculating Extreme Cold Weather Temperature guidance is still being used for calculation of the ECWT. However, as of August 2025, the National Oceanic and Atmospheric Administration (NOAA) stopped providing temperature data. As a result, Automated Surface Observing Systems (ASOS) data is being used as an alternative, and instructions for ASOS begin on page 18 of the guidance document.
To further support EOP-012 implementation, the ERO Themes and Best Practices for Extreme Weather was published October 1, 2026. NERC and the six Regional Entities published the guidance based on compliance with EOP-012-2 and EOP-012-3 relating to cold weather preparedness. These themes and best practices relate directly back to focus areas of cold weather facility walkdowns and are an excellent resource to advance compliance.
Recommendations for Periodic Data Submittals (PDSs)
EOP-012-3 became effective October 1, 2025, and updated multiple items, including Generator Cold Weather Constraint terminology, Corrective Action Plans (CAPs), CAP extensions that require Compliance Enforcement Authority (CEA) approval, and detailed Generator Cold Weather Constraint declarations with the addition of Attachment 1. Some recommendations for PDSs are included below for timely submission and evaluation purposes.
For Constraints
- Perform timely evaluation and action when a Generator Cold Weather Events occur.
- Review carefully the EOP-012-3 standard language including Attachment A before submission.
- Complete all parts of the data submission form (found in Align) according to the instructions provided in the spreadsheet before submitting to the Secure Evidence Locker (SEL).
- Provide current Original Equipment Manufacturer (OEM) documentation that supports the constraint.
- Ensure the constraint is submitted within 45 calendar days of determining that the Generator Cold Weather Constraint is applicable (other than R2 constraints) per R8.
For CAP Extensions
- Carefully review the EOP-012 Standard language for CEA submission deadlines and supporting evidence.
Positive Trends
Since Winter Storm Uri, there have been positive compliance activity trends and better understanding of expectations. The Federal Energy Regulatory Commission’s (FERC’s) Reliability Spotlight on Cold Weather Preparedness lists multiple goals as completed or progressing as expected since winter 2021. There has also been an improving trend since the Electric Reliability Council of Texas (ERCOT) weatherization inspections began.
Following Winter Storm Uri, coordination between agencies, such as ERCOT, the Public Utility Commission of Texas (PUCT), the Texas Commission on Environmental Quality (TCEQ), the Texas Division of Emergency Management (TDEM), and the Department of Energy (DOE) have improved. Performance during Winter Stom Fern indicated the increased coordination and collaboration had positive results as there were no Energy Emergency Alerts (EEAs) or systemwide power outages despite the extreme conditions.
Weather Forecast
Across the board, forecasts are predicting a warmer and wetter than average winter season, excluding short-term extremes due to a “super” El Niño influence. Despite the mild weather predictions, staying vigilant on cold weather preparedness will continue the positive compliance trend.
Following guidance on areas of improvement, best practices, and recommended steps will aid in improving compliance with EOP-012-3. If you have any questions regarding EOP-012-3 or any other Reliability Standards, please contact information@texasre.org.
Resources:
EOP-012-4 Technical Rationale
Calculating Extreme Cold Weather Temperature
ERO Enterprise Themes and Best Practices for Extreme Weather
2026 ERO Enterprise Periodic Data Submittal Schedule
Generator Cold Weather CAP Extension and Constraint Process
