There have been a number of questions about whether there are any kind of standards or requirements for generator winterization at either the state or federal level. From what I can tell, the answer is a firm "not really". Again, FERC/NERC's 2011 report is instructive. 1/
I don't have the bandwidth/resources to run this all the way to ground, but I did dig up this letter that FERC sent to NERC in June 2012. It explains that the 2011 report found a gap in federal, state, and regional standards w/ respect to winterization. 2/ nerc.com/FilingsOrders/…
In that letter, FERC asks NERC for an update on "the initiative to modify the Reliability Standards to address winterization and related issues. NERC's response (linked here) explains it had opened a "Standards Authorization Request (SAR)." 3/ nerc.com/FilingsOrders/…
A SAR basically starts the process of developing a potential new reliability standard, which if approved by NERC + FERC, becomes a requirement.
This SAR, though, was terminated in 2013 in favor of developing a detailed "reliability guideline." 4/ nerc.com/pa/Stand/Proje…
This SAR, though, was terminated in 2013 in favor of developing a detailed "reliability guideline." 4/ nerc.com/pa/Stand/Proje…
This is where I lose the trail. Docket No. AD11-9-000 contains many additional inquiries from FERC and responses from Texas Regional Entity the regional reliability entity for ERCOT) and others on winterization issues. 5/
Slow eLibrary and other commitments mean I can't read through them all, but I'm sure FERC and NERC are going to dig back through all of that to figure out where their 2011 recommendations went.
I remain confident that "not really" is the answer. 6/6
I remain confident that "not really" is the answer. 6/6
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