EPSA and P3 File Comments on NERC Extreme Cold Weather Standard (RD23-1)

EPSA and P3 filed the attached comments at FERC on NERC’s Proposed Extreme Cold Weather Standards (RD23-1). While generally supportive of NERC’s efforts, these comments outline the legal and operational issues with Requirements R1 and R2 of the proposed standard. EPSA and P3 request the standard be remanded back to NERC and revised to remove Requirements 1 and 2, with a directive that NERC instead require Balancing Authorities to ensure sufficient quantities of weather resilient generation are available. EPSA and P3 also ask that that the Commission ensure that competitive generators have an opportunity to recover their prudently incurred costs associated with complying with any final standards.