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Commissioner Clements’ Dissent Regarding Transcontinental Gas Pipe Line Company, LLC, et al.

Docket Nos. CP22-502-000, CP22-503-000

Federal Energy Regulatory Commission
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Reliability Spotlight: Cold Weather Preparedness


FERC and the North American Electric Reliability Corporation (NERC) have taken unprecedented measures to review and analyze, and seek improvements to, cold weather operations of energy delivery systems in the wake of Winter Storm Uri in 2021 and Winter Storm Elliott in 2022. We also enlisted the help of the North American Energy Standards Board (NAESB) in finding ways the electric and natural gas industries can work more closely together, particularly when freezing weather hits. This page tracks and provides updates to the status of recommendations that have come from the FERC-NERC winter storm analyses.

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Legend

πŸ”΅ Completed  |  πŸŸ’ Progressing as Expected  |  🟑 More Progress Needed   

Recommendation Category Recommendation Topics Summary Status
Freeze Protection Cold Weather Reliability Standards, Rules for:  
Electric Generation πŸ”΅
Natural Gas Facilities 🟒
 
Gas-Electric Coordination Identify Actions: Forums, Work Groups πŸ”΅
Develop and Implement Actions πŸ”΅
 
Grid Operations Bi-directional Power Transfer Studies 🟒
Load Shed Coordination and Training πŸ”΅
Load Forecasting and Operational Planning πŸ”΅
 
State-Level Energy Efficiency Improvement Incentives 🟒
Enhance Emergency Response Centers 🟒
Additional Deployable Demand Response 🟒
 
Further Studies ERCOT Additional Interconnection Links 🟒
Blackstart Cold Weather Reliability πŸ”΅
Mechanical/Electrical Caused Outages 🟒
Low Frequency Effects - Generation 🟒
Dynamic Stability During Elliott Event 🟒
Natural Gas Reliability for Grid Support 🟒
Critical Natural Gas Infrastructure identification 🟒
 

Freeze Protection

Electric Generation

Reliability Standards developed, approved
(Uri Report Key Recommendation 1)

  • In August 2021, Commission approved first set of Reliability Standards requiring generator cold weather preparedness plans

  • In February 2023, Commission approved cold weather preparedness Standard EOP-012-1 (effective October 1, 2024), aimed to address the first part of the Uri Report's key recommendation for Reliability Standards

  • In February 2024, Commission approved Standards EOP-011-4 and TOP-002-5 addressing additional parts of the Uri Report's key recommendation for Standards

  • In June 2024 , Commission approved Standard EOP-012-2, with directives for further modifications,  that addressed the remaining parts of the key recommendation for Reliability Standards from the Uri Report.
  • In September 2025, Commission approved Standard EOP-012-3 (effective October 1, 2025), which further improved on the approved generator cold weather preparedness in EOP-012-2 through enhanced and expanded requirements.

Generator cold weather reliability guidance and monitoring efforts to date
(Uri Report Recommendations 3, 4, 12, and 23; Elliott Report Recommendation 1)

  • In April 2022, hosted joint FERC, NERC and Regional Entities Technical Conference: Improving Winter-Readiness of Generating Units

  • In May 2023, NERC issued its first Level 3 Alert containing essential actions addressing cold weather preparedness for extreme weather events, with the overwhelming majority of Generator Owners responding that 91-100% of their capacity would be capable of operating at their Extreme Cold Weather Temperature as defined in Standard (EOP-012-1) by Winter 2023-2024

  • Winter 2023-2024 - cold weather preparedness verification actions by NERC, focused on highest-risk generating units: 

    • Ongoing engagement with Generator Owners ahead of Winter 2023-2024 through meetings, webinars, workshops, on-site visits, surveys, and partnering with Reliability Coordinators

    • Ongoing evaluation of cold weather events:  FERC-NERC-Regional Entity joint review of the January 2024 Arctic Storms Gerri and Heather; results presented at April 2024 Commission Open Meeting

  • In November 2024, NERC and generator equipment manufacturers held a Cold Weather Technical Conference and discussed generator winterization challenges.

Natural Gas Facilities

Establish rules and practices for natural gas facilities' cold weather preparedness
(Uri Report Recommendations 5, 6, and 14; Elliott Report Recommendation 4)

  • In August 2022, Texas Railroad Commission adopted rule to require critical natural gas facilities on the Texas Electricity Supply Chain Map to implement weather emergency preparation measures

Other state- and/or federal-level actions regarding establishing rules for natural gas facilities cold weather reliability

  • State-level: Uri/Elliott recommendations tracking team is working with relevant state entities' staff to gain understanding of state-level progress


Gas-Electric Coordination (Regional and State-Level)

Identify Actions: Forums, Work Groups

August 2022 - NAESB Gas-Electric Harmonization Forum
(Uri Report Recommendation 7 and Further Study Recommendation 24)

  • North American Energy Standards Board (NAESB) convened a public Gas-Electric Harmonization Forum to develop concrete actions to improve reliability of the natural gas infrastructure system necessary to support the Bulk Electric System, final report issued July 2023

September 2022 - FERC-Led New England Winter Gas-Electric Forum
(Uri Report Recommendation 7 and Further Study Recommendation 24)

  • The Commission hosted a New England Winter Gas-Electric Forum to discuss the electricity and natural gas challenges faced historically during New England winters to increase understanding

June 2023 - FERC-Led New England Winter Gas-Electric Forum
(Uri Report Recommendation 7 and Further Study Recommendation 24)

  • The Commission hosted a second New England Winter Gas-Electric Forum to discuss solutions to the electric and gas challenges facing the New England region

Understanding Natural Gas Contract Risks
(Uri Report Recommendation 8)

  • NERC's Electric Gas Working Group (EGWG) developed a Fuel Assurance Reliability Guideline to help registered entities fully understand fuel supply chain risks, and offer additional conditions and constraints, especially during extreme events, to consider when performing studies. Guideline issued September 2023

  • In March 2024, the Commission established a Federal-State Current Issues Collaborative to explore cross-jurisdictional issues relevant to FERC and state utility commissions. The first public meeting of the Collaborative was held on November 12, 2024, and the second public meeting of the Collaborative will be held on April 30, 2025.

Develop and Implement Actions

November 2023 - NARUC Gas-Electric Alignment for Reliability (GEAR) Working Group
(Findings from NAESB Gas-Electric Harmonization Forum, the Reliability Alliance Report developed by NGSA, INGAA and EPSA, and the FERC/NERC analyses of Winter Storms Uri and Elliott)

  • Convened by National Association of Regulatory Utility Commissioners (NARUC) and chartered in November 2023 for 15 months to "bring together state regulators and industry representatives to develop solutions to better align the gas and electric industries to maintain and improve the reliability of the gas and electric energy system."

December 2023 - NAESB gas-electric coordination business practice standards development
(Elliott Report Recommendation 5)

  • Participants prepared multiple work papers, some of which include proposed revisions to the NAESB Wholesale Gas Quadrant Business Practice Standards. Proposals for consideration include communication protocols to provide notice of weather conditions that could impact or are impacting upstream natural gas production, processing, and gathering; enhanced granularity of locational information provided in critical notices; and centralized posting of gas-electric coordination information by interstate pipelines

  • In Docket No. RM96-1, the North American Energy Standards Board submitted a report to inform the Commission of the modifications to the NAESB Wholesale Gas Quadrant (WGQ) Business Practice Standards, revision of NAESB WGQ Standard No. 4.3.23 and addition of NAESB WGQ Standard No. 0.3.30 and NAESB WGQ Standard No. 5.3.74.


Grid Operations

Perform bi-directional seasonal transfer studies
(Uri Report Recommendation 20)

  • 2023: NERC's Reliability Assessment Subcommittee (RAS) completed survey of relevant entities to gain additional insight; 2024: bi-directional seasonal transfer studies for training is included in NERC's Real Time Operations Subcommittee (RTOS) workplan

Load shed coordination and training
(Uri Report Recommendations 10, 21, and 22)

  • September 2022: Electric Reliability Council of Texas (ERCOT) approved additional underfrequency load shed stage (anti-stall stage) to provide time for system operators to respond to grid conditions; Western Interconnection also incorporated anti-stall load shed stage

  • 2023: Operator training rotational firm load shed simulations - completed through NERC RTOS

  • Planned for 2023-2024: RTOS; workplan includes review and improve rotational load shed plans as needed, in collaboration with NERC RAS

Load forecasting and operational planning
(Uri Report Recommendations 9, 16, and 17; Elliott Report Recommendations 8, 9, and 10)

  • Winter 2021-2022: NERC modified its Winter Reliability Assessment to incorporate expanded risk analyses for the assessment regions to capture additional extreme condition scenarios to better predict reserve levels that could be expected during upcoming winter peak conditions

  • 2022-2023: ERCOT, Midcontinent Independent System Operator (MISO) and Southwest Power Pool (SPP) made responsive changes based on the Uri report's associated recommendations to improve winter peak load forecasts and reserve margin calculations

  • June 2022: NERC Energy Reliability Assessment Task Force/Working Group (ERAWG) requested development of Reliability Standards to require entities to perform energy reliability assessments to evaluate energy assurance and develop Corrective Action Plan(s) to address the identified risks for both planning and operations time horizons associated with unassured energy supplies, including the timing an inconsistent output from variable energy resources, fuel location, and volatility in forecasted load, which can result in insufficient amounts of energy on the system to serve electrical demand. March 2023, white paper completed

  • In December 2024, NERC Energy Reliability Assessment Task Force/Working Group (ERAWG) published the second volume of Considerations for Performing an Energy Reliability Assessment, a technical reference detailing how to perform an Energy Reliability Assessment, including different methods for building analysis tools, how metrics can be defined in terms of energy, and approaches to corrective actions when those metrics cannot be met.

  • In June 2025, NERC completed its report on load forecasting sessions that occurred during the September 2024 Reliability and Security Technical Committee meeting. The report was released publicly in September 2025. The publication discusses strategies on load forecasting changes and improvements to address the Winter Storm Elliott recommendations.


State-Level 

Energy Efficiency Improvement Incentives
(Uri Report Recommendation 19)

Enhance Emergency Response Centers
(Uri Report Recommendation 15)

Additional Deployable Demand Response
(Uri Report Recommendation 18)

  • Uri/Elliott recommendations tracking team is working with relevant state entities' staff to gain understanding of progress related to state-level related recommendations

Further Studies

ERCOT - Additional Interconnection Links
(Uri Report Recommendation 25)

  • December 2023: ERCOT published Report on Existing and Potential Electric System Constraints and Needs which describes two high voltage direct current (HVDC) ties currently proposed: a 3,000 MW tie to Eastern Interconnection, and a 1,500 MW transmission line that would connect ERCOT to the Western Interconnection

Blackstart cold weather reliability
(Uri Report Recommendation 26; Elliott Report Recommendation 3)

  • ERCOT Interconnection: April 2022 - FERC, NERC and Regional Entity Staff evaluated the availability of blackstart resources in the ERCOT Interconnection during extreme cold weather conditions and published their report December 2023
  • Eastern and Western Interconnections:  November 2025 - NERC and Regional Entity Staff published a study about blackstart resource availability and readiness during cold weather conditions and included nine new recommendations to enhance cross-industry coordination, improve situational awareness, strengthen regulatory frameworks, and ensure the robustness of blackstart capabilities.

Low frequency effects-generation
(Uri Report Recommendation 13 and 27)

  • 2022-2023: NERC staff began review of relevant information from Eastern Interconnection, and identified boiler control contributions to frequency response; additional statistics are being gathered to determine next steps

Critical natural gas infrastructure identification
(Uri Report Recommendation 28)

  • Texas adopted an electricity supply chain map of critical interdependent natural gas and electric infrastructure in April 2022 
  • February 2024: Commission approved Reliability Standard EOP-011-4 which requires prioritization of identified critical natural gas infrastructure loads from load shed

Technical review of generator mechanical/electrical-caused outages during cold weather
(Elliot Report Recommendation 2)

  • NERC is in the process of contracting with a third party to perform technical review

Natural gas reliability for grid support
(Uri Report Further Study Recommendation 24, Elliott Report Recommendation 7)

  • Department of Energy (DOE) is conducting analyses regarding how single points of failure in natural gas infrastructure could potentially impact the electric grid
  • November 2023 - Northeast Power Coordinating Council launched a northeastern regional gas infrastructure study to evaluate fuel supply to the region's electric generation. The study published in January 2025, considered the gas supply and pipeline constraints during extreme and protracted winter weather events during the winter peak heating season (December through February 2024-2025, 2027-28, and 2032-33)
  • Also, for Uri Further Study Recommendation 24, see Gas-Electric Coordination category

Examine dynamic stability of Eastern Interconnection during Winter Storm Elliott event
(Elliot Report Recommendation 11)

  • January 2024 - Eastern Interconnection Planning Collaborative (EIPC) began a comparative analysis of the system inertia and frequency data during Winter Storm Elliott with the conditions it had studied in the 2022 EIPC Frequency Response Study.
  • In November 2024, NERC released its Interregional Transfer Capability study to inform the potential need for more electric transmission transfer capability to enhance reliability.

This information was prepared by the staff of the Federal Energy Regulatory Commission (FERC) in consultation with staff from the North American Electric Reliability Corporation (NERC), and does not necessarily reflect the views of the Commission.

Contact Information


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    Email: [email protected]

Quick Links


  • Chairman's Reliability Report | A Year in Review
  • 2023 Reliability Report
  • 2021 Winter Storm Uri Report
  • 2022 Winter Storm Elliott Report
  • January 2024 Arctic Storms Gerri and Heather Review

This page was last updated on February 05, 2026

Sunshine Notice | April 2024 Commission Meeting

Event Details

Sunshine Notice | May 13, 2024 Commission Meeting

Event Details

Commission Meeting

May 13, 2024 Open Meeting

Notational Orders 2024-04-18

Docket Nos.

04/19/2024

Notational Order 2023-04-19

Docket No. ER24-722-001; ER24-521-001

Electric Power Supply Association v. FERC

S. Ct. No. 23-773

04/22/2024

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