First Things RFirst: November 2025

Expert analysis for a more reliable, secure and resilient electric grid, plus news and updates for RF stakeholders.

Insights & Analysis

The Lighthouse: CIP low impact from the ground up – Part 8, Developing your low impact cyber security plans

In Part 8 of Lew Folkerth’s series exploring the NERC CIP Standards applicable to low impact BES Cyber Systems, he turns his focus to cyber security plans.

Click here to read more

The Lighthouse: CIP low impact from the ground up – Part 8.1, Developing your security awareness plan

In Part 8.1 of Lew Folkerth’s series exploring the NERC CIP Standards applicable to low impact BES Cyber Systems, Lew tackles Section 1 of NERC Reliability Standard CIP-003-9 (Security Management Controls) Attachment 1, which covers cyber security awareness.

Click here to read more

Regulatory Affairs: Grid reliability news we’re tracking

The latest regulatory headlines we’re tracking include:

• FERC issues Order 912 directing additions to CIP supply chain risk management standards
• FERC holds annual Reliability Technical Conference
• FERC issues Lessons Learned Report from FERC-led CIP audits

Click here to read more

News & Updates

NERC publishes Winter Reliability Assessment

NERC’s 2025–2026 Winter Reliability Assessment finds that much of North America is again at an elevated risk of having insufficient energy supplies to meet demand in extreme operating conditions. Although resources are adequate for normal winter peak demand, any prolonged, wide-area cold snaps will be challenging. This is largely due to rising electricity demand, which has grown by 20 GW since last winter, significantly outpacing winter on-peak capacity. This, coupled with the changing resource mix, is affecting the winter outlook.

Click here to read more

Lessons Learned from Certification Activities

The ERO Enterprise shared a presentation on lessons learned from regional certifications at the NERC Organization Registration and Certification Subcommittee (ORCS) meeting in July. Some of the key points from the presentation included:

Energy Management Systems (EMS) changes:

• Communicate clearly with vendors and emphasize important specifications when upgrading your EMS. A lack of communication can lead to slow response to challenges, which are sometimes also due to vendor resource issues.
• Have a contingency plan for any EMS features that the vendor cannot provide.
• Make sure that critical documentation is in place including any needed internal controls.

Control Center changes:

• Plan for the possibility that Control Center construction companies may not be reliable when it comes to meeting deadlines, such as go-live dates, potentially due to supply chain issues or other challenges.
• Ensure applicable NERC CIP Standard Requirements are in place such as Electronic Security Perimeters, Physical Security Perimeters, etc.

Preparation for certification activities:

• Communicate future changes with your Regional Entity early, i.e. if you know a project such as an EMS change is taking place, notify RF (and other regions if you are a Multi-Regional Registered Entity [MRRE]) at least one year prior to implementation. (See Certification Annual Reminder to RF Entities for more information)
• Engage with your Regional Entity as early as possible to allow time to perform the activity in accordance with the NERC Rules of Procedure and ensure certification approval meets your needs for implementation. (See Certification Activity Presentation for more information)

To share feedback with our team, including lessons learned to improve our process, or for any questions about certifications, email entityengagement@rfirst.org. Questions can also be submitted through RF’s Assist Visit Program.

For more information on the Certification Process, see ROP App. 5A, Sections IV and V. Additional information is also available on our website here. Please fill out and submit an application to entityengagement@rfirst.org when planning a change, per ROP App. 5A, Sec. V.

Upcoming Events

Dec. 15, 2-3:30 p.m. ET | Tech Talk with RF

Save the date for our December edition of Tech Talk with RF on Monday, Dec. 15! Stay tuned for agenda details to be posted on our website calendar and LinkedIn feed.

Event details

Feb. 23-25, 2026 | RF Internal Controls Workshop

Join ReliabilityFirst on Feb. 23-25 in Cleveland for a dynamic and engaging Internal Controls Workshop that kicks off a power packed week focused on Compliance Monitoring (CIP and O&P) and Enforcement.

This interactive experience features small group discussions, opportunities to share industry insights, and a flexible format that lets you choose your own learning tracks. Whether you prefer to explore a variety of topics or dive deep into specific areas, this workshop is designed to foster meaningful conversations and practical takeaways.

Event details

Feb. 25-26, 2026 | ERO Women’s Leadership Conference

Back-to-back with our Internal Controls Workshop, be sure to stick around for the 2026 ERO Women’s Leadership Conference!

There will be an evening reception on Feb. 25 followed by the conference on Feb. 26.

RF is proud to serve as the host Regional Entity for this year’s event, which will be held in-person for the first time! Expect:

• Panels focused on professional development, mentorship, empowerment, and insights tailored to the energy sector
• Networking
• Professional head shot photo opportunity
• Additional resources

Event details

To explore our full calendar of upcoming events, click here.

The post First Things RFirst: November 2025 appeared first on ReliabilityFirst.

Recent regulatory headlines we’re tracking include:

FERC issues Order 912 directing additions to CIP supply chain risk management standards

FERC has issued a final rule (Order 912) directing NERC to develop new or modified Reliability Standards within 18 months to address “gaps” in the CIP supply chain risk management (SCRM) standards.  The Order states that these new or modified standards must address: 1) the sufficiency of responsible entities’ supply chain risk management plans related to how they identify and respond to supply chain risks; and 2) how the SCRM standards apply to protected cyber assets (PCAs). FERC states that the current SCRM standards provide a baseline of protection but must be enhanced to keep up with the changing threat landscape.

FERC holds annual Reliability Technical Conference

FERC held its annual Reliability Technical Conference on Oct. 21. The conference opened with comments from the commissioners, who discussed the critical importance of reliability issues and risks posed by data centers and large load growth. NERC President & CEO Jim Robb then presented on the State of Reliability, noting that while reliability remains high, there is an increasing number of near misses and a “five alarm fire” with risks related to resource adequacy, permitting issues, extreme weather, natural gas interdependencies, demand growth, and security. The first panel focused on leadership priorities, with panelists from NERC, Vistra Corp., NARUC, Invenergy, AEP, ComEd, and Duke Energy. The industry leaders shared solutions they are employing, such as uprating power plants for additional capacity and utilizing Grid Enhancing Technologies (GETs).

During the second panel, “Ensuring Reliability with Large Loads,” NERC Vice President Mark Lauby shared the various actions the ERO Enterprise is taking to address reliability risks posed by rapidly increasing large loads, including a NERC alert with guidance on interconnecting loads and ongoing work of the NERC Large Loads Taskforce. There was discussion among the panelists of the importance of certainty and being able to plan for the amount of large loads coming online, and the need for robust modeling and load forecasting. A full recording of the conference is available here.

FERC issues Lessons Learned Report from FERC-led CIP audits

FERC staff issued the 2025 Lessons Learned from Commission-Led CIP Reliability Audits report, an anonymized summary report with takeaways from FERC-led CIP audits from the past year.  The report states that while entities met most CIP requirements during these audits, FERC identified potential noncompliance and security risks, as well as voluntary cyber security recommendations.

There were three key lessons learned in the report: first, for CIP-002-5.1a (Cyber Security — BES Cyber System Categorization), R1, BES Asset identification and categorization procedures should include distributed energy resources (DERs) when determining the impact rating of a control center. Second, for CIP-003-8 (Cyber Security — Security Management Controls), CIP-006-6 (Cyber Security — Physical Security of BES Cyber Systems), and CIP-010-4 (Cyber Security — Configuration Change Management and Vulnerability Assessments), entities should perform due diligence and careful oversight when relying on third parties to perform compliance duties. Finally, for CIP-004-7 (Cyber Security — Personnel & Training) and CIP-010-4, entities should consider compliance risks associated with cloud services (for example, some entities could not provide personnel risk assessments for employees of the cloud service provider, or baselines for cloud-based systems under CIP-010). Each of these lessons learned has suggested mitigation actions listed with them in the report, along with references to additional guidance documents.

The post Regulatory Affairs news highlights: November 2025 appeared first on ReliabilityFirst.

State Energy Insights: November 2025

Grid Reliability and Regulatory Updates from ReliabilityFirst

News & Updates

FERC holds annual Reliability Technical Conference

FERC held its annual Reliability Technical Conference on Oct. 21. The conference opened with comments from the commissioners, who discussed the critical importance of reliability issues and risks posed by data centers and large load growth.

NERC President & CEO Jim Robb then presented on the State of Reliability, noting that while reliability remains high, there is an increasing number of near misses and a “five alarm fire” with risks related to resource adequacy, permitting issues, extreme weather, natural gas interdependencies, demand growth, and security.

The first panel focused on leadership priorities, with panelists from NERC, Vistra Corp., NARUC, Invenergy, AEP, ComEd, and Duke Energy. The industry leaders shared solutions they are employing, such as uprating power plants for additional capacity and utilizing Grid Enhancing Technologies (GETs).

During the second panel, “Ensuring Reliability with Large Loads,” NERC Senior Vice President and Chief Engineer Mark Lauby shared the various actions the ERO is taking to address reliability risks posed by rapidly increasing large loads, including a NERC alert with guidance on interconnecting loads and ongoing work of the NERC Large Loads Taskforce. There was discussion among the panelists on the importance of certainty and being able to plan for the amount of large loads coming online, and the need for robust modeling and load forecasting. A full recording of the conference is available here.

Federal and State Current Issues Collaborative meeting on energy permitting postponed

Due to the government shutdown, FERC postponed the next meeting of the Federal and State Current Issues Collaborative from Nov. 12 to February 2026 during the NARUC Winter Summit.

The collaborative was created by FERC and the state public utility commissions across the country to discuss and explore cross-jurisdictional issues of interest. FERC has stated that the topic of the meeting will be energy infrastructure permitting, and a more detailed agenda will be released in the future.

DOE issues Notice of Funding Opportunity for coal plant refurbishing

The DOE on Oct. 31 announced a Notice of Funding Opportunity (NOFO) for up to $100 million in federal funding to refurbish and modernize the nation’s existing coal power plants.

The funding will be administered by DOE’s National Energy Technology Laboratory under the Office of Fossil Energy and Carbon Management. The NOFO solicits proposals in three technical areas: advanced wastewater management, dual-fuel switching capability, and coal-natural gas cofiring systems.

This follows DOE’s announcement on Sept. 29 of a $625 million broader investment across multiple coal-related initiatives, including plant recommissioning, rural electrification projects, and related infrastructure support. The current NOFO represents a subset of that September funding stream, with specific technical deliverables and performance milestones tied to demonstration-scale projects.

Upcoming Events

Nov. 17, 2-3:30 p.m. ET | Tech Talk with RF

Join us for our next edition of Tech Talk on Monday, Nov. 17. Here’s what’s on the agenda:

Supply chain challenges
Jeff Craigo, Senior Vice President, Operations and Risk, RF

Eric Seidler, SVP, Corporate Safety, Security and Operational Oversight, Ameren

Jeff Craigo and Eric Seidler will discuss the impact of supply chain challenges on electric grid reliability, including equipment lead times, tariffs, the labor market, and mitigation strategies. The Bulk Electric System (BES) is not immune to supply chain risks, which can compromise or impact the availability of equipment, tools, and resources that results in the delay or disruption of system operations.

CIP standards update
Lew Folkerth, Principal Reliability Consultant, External Affairs, RF

FERC announced action in three areas of the CIP standards in September. Lew will provide a summary of these actions and a discussion of the status of other CIP development efforts.

Event details

Feb. 25-26, 2026 | ERO Women’s Leadership Conference

You won’t want to miss the 2026 ERO Women’s Leadership Conference! ReliabilityFirst is hosting next year’s event in-person in Cleveland, with an evening reception on Feb. 25 followed by the conference on Feb. 26.

We are thrilled to present an exciting lineup of speakers, including:

• Joanna McDaniel Burkey, Principal, Flat Rock Strategic Advisors
• Lesley Evancho, Chief Human Resources Officer, EQT Corporation
• Mèlika Carroll, VP of Global Government Affairs and Public Policy, Cohere
• Lisa Barton, President & CEO, Alliant Energy
• Sara Patrick, President & CEO, Midwest Reliability Organization
• Bluma Sussman, VP, Stakeholder Engagement, North American Electric Reliability Corporation (NERC)/E-ISAC
• Holly Hawkins, VP, General Counsel & Corporate Secretary, SERC Reliability Corporation
• Diane Holder, VP of Engineering & Strategic Engagement, RF
• Niki Schaefer, VP & General Counsel, RF
• Beth Dowdell, Senior Director of Corporate Services, RF
• Sarah Eppink, MOD, BCC, Leadership Coach and Talent Development Consultant, Aisling Group
• Julia Kious Zabell, Executive Director of Weatherhead Executive Education, Case Western Reserve University
• Chris Guiney, Partner, CarterBaldwin Executive Search
• Tod Podl, Physician, University Hospitals

Event details

The post State Energy Insights from ReliabilityFirst: November 2025 appeared first on ReliabilityFirst.

First Things RFirst: October 2025

Expert analysis for a more reliable, secure and resilient electric grid, plus news and updates for RF stakeholders.

Insights & Analysis

RF shares analysis of August 2025 Baltimore load shed event

ReliabilityFirst (RF) on Tuesday published the August 2025 Baltimore Load Shed Event ReliabilityFirst After Action Analysis. The report details and analyzes the Aug. 11, 2025 bulk power system disturbance that impacted approximately 4,000 customers in the Baltimore area for a duration of 28 minutes.

Click here to read more

ReliabilityFirst 2024 Misoperation Performance and Improvement Opportunities

ReliabilityFirst is committed to increasing stakeholder awareness of Protection System Misoperation performance, as they pose a reliability risk to the Bulk Electric System by increasing the potential severity of an event when they occur. Here’s a high-level look at the current Misoperations risk posture within the ReliabilityFirst footprint and the ongoing efforts to monitor and improve performance as risk levels evolve.

Click here to read more

Regulatory Affairs: Grid reliability news we’re tracking

The latest regulatory headlines we’re tracking include:

• FERC issues NOPRs proposing to approve revisions to 11 NERC CIP Standards
• U.S. House of Representatives passes GRID Power Act
• U.S. House of Representatives introduces State Energy Accountability Act

Click here to read more

News & Updates

What to know about new EOP-012-3 cold weather preparedness standard

In late September, FERC approved the latest version of NERC’s cold weather preparedness standard (EOP-012-3) with an effective date of Oct. 1, 2025. Periodic Data Submittals associated with EOP-012-3 should be submitted through Align. The 2026 Periodic Data Submittal Schedule is available here. 

NERC submitted EOP-012-3 to FERC on April 10, 2025, in response to FERC’s directive that it develop targeted modifications to EOP-012-2. Specifically, FERC directed NERC to clarify the term “generator cold weather constraint” (situations in which a generator owner may declare that a specific freeze protection measure would result in a net loss of reliability on the grid) and ensure that the ERO confirms the validity of each constraint, along with clarifying requirements around corrective action plans.  

In EOP-012-3, NERC proposed a new, clearer definition for generator cold weather constraints that removed ambiguous references to “cost,” “reasonable cost,” “unreasonable cost,” and “good business practices.” EOP-012-3 also introduces the concept of a compliance abeyance period for the requirement that Generator Owners calculate the extreme low temperature for their generating units. The FERC order approving EOP-012-3 is available here. 

NERC Modernization of Standards Processes and Procedures Task Force to post draft recommendations for comment Oct. 21

The NERC Modernization of Standards Processes and Procedures Task Force (MSPPTF) will post draft recommendations for transforming the standards development process for comment from Oct. 21 to Nov. 10. The draft recommendations will be informed by significant stakeholder input received on the Potential Options for Transforming the Reliability Standards Development Framework white paper. A stakeholder webinar will take place on Oct. 20 to discuss and provide context for the draft recommendations.  

While the written public comment period will close on Nov. 10, the task force will also host two in-person forums to provide additional insight into the rationale behind the draft recommendations and will offer stakeholders the opportunity to provide more perspective. These forums will also offer a virtual option. Those attending virtually will be able to submit questions through the webinar chat/Q&A feature. 

The task force will continue its extensive program of external engagements that include a mix of in-person and virtual meetings. Task force members will also present to NERC standing committees, engage directly with trade organizations, and host other informal discussions to gather input from stakeholders. Upcoming engagements are posted and will be regularly updated on the MSPPTF web page. 

The input process concludes at the end of November to allow the MSPPTF to develop the final recommendations for transforming the Reliability Standards framework, which will be presented at the Feb. 12, 2026, NERC Board of Trustees meeting. 

NERC issues Level 2 Alert on large load interconnection, study, commissioning, and operations

In September, NERC issued a Level 2 Alert on large load interconnection, study, commissioning, and operations to address reliability risks from rapidly changing, high-demand loads like data centers.

The Level 2 Alert was issued in response to a series of disturbances where unexpected large load output reduction occurred between 2024-2025, and was sent to Distribution Providers (DP), Resource Planners (RP), Transmission Owners (TO), Transmission Operators (TOP), Transmission Planners (TP), Balancing Authorities (BA), Planning Coordinators (PC), and Reliability Coordinators (RC).

Responses to the questions included in the NERC Alert are required to be submitted via the NERC Alert System by Jan. 28, 2026, 12 a.m. ET.

Upcoming Events

Oct. 20, 2-3:30 p.m. ET | Tech Talk with RF

Coming up on the October edition of Tech Talk with RF, we’re focusing on cyber security for National Cyber Security Awareness Month.

Here’s what’s on the agenda:

• How to address the risk of insufficient trained OT cyber security personnel
  Mike Holcomb, Fellow, Director – ICS/OT Cybersecurity, Fluor
• ICS security without the guesswork: a risk-first approach 
  Stacy Bresler, Managing Partner, Archer Energy Solutions
• CIP standards update
  Lew Folkerth, Principal Reliability Consultant, External Affairs, RF 

Event details

Nov. 18-19, 2025 | GridEx VIII

GridEx is the largest grid security exercise in North America, hosted every two years by the NERC Electricity Information Sharing and Analysis Center (E-ISAC). It offers E-ISAC member and partner organizations a forum in which to practice how they would respond to and recover from coordinated cyber and physical security threats and incidents.

The last event in 2023 saw more than 15,000 participants come together from approximately 250 North American organizations, including the electric industry, cross-sector partners from gas and telecommunications, and U.S. and Canadian government partners.

Event details

Feb. 23-25, 2026 | RF Internal Controls Workshop

Join ReliabilityFirst on Feb. 23-25 in Cleveland for a dynamic and engaging Internal Controls Workshop that kicks off a power packed week focused on Compliance Monitoring (CIP and O&P) and Enforcement.

This interactive experience features small group discussions, opportunities to share industry insights, and a flexible format that lets you choose your own learning tracks. Whether you prefer to explore a variety of topics or dive deep into specific areas, this workshop is designed to foster meaningful conversations and practical takeaways.

Event details

Feb. 25-26, 2026 | ERO Women’s Leadership Conference

Back-to-back with our Internal Controls Workshop, be sure to stick around for the 2026 ERO Women’s Leadership Conference!

There will be an evening reception on Feb. 25 followed by the conference on Feb. 26.

RF is proud to serve as the host Regional Entity for this year’s event, which will be held in-person for the first time! Expect:

• Panels focused on professional development, mentorship, empowerment, and insights tailored to the energy sector
• Networking opportunities
• Professional development resources

Event details

To explore our full calendar of upcoming events, click here.

The post First Things RFirst: October 2025 appeared first on ReliabilityFirst.

Recent regulatory headlines we’re tracking include:

FERC issues NOPRs proposing to approve revisions to 11 NERC CIP Standards

In two Notices of Proposed Rulemaking (NOPR) issued at its September open meeting, FERC proposed to approve 11 new NERC CIP Standards intended to allow utilities to use virtualization technology, along with a further modification to one of those standards that would improve cyber security at low-impact grid-connected cyber systems. Along with four new and 18 revised definitions for the NERC Glossary of Terms, the NOPRs touched almost every CIP Standard including:

• CIP-002-7 (Cyber Security – BES Cyber System Categorization)
• CIP-003-10 (Cyber Security – Security Management Controls)
• CIP-004-8 (Cyber Security – Personnel and Training)
• CIP-005-8 (Cyber Security – Electronic Security Perimeters)
• CIP-006-7 (Cyber Security – Physical Security of BES Cyber Systems)
• CIP-007-7 (Cyber Security – Systems Security Management)
• CIP-008-7 (Cyber Security – Incident Reporting and Response Planning)
• CIP-009-7 (Cyber Security – Recovery Plans for BES Cyber Systems)
• CIP-010-5 (Cyber Security – Configuration Change Management and Vulnerability Assessments)
• CIP-011-4 (Cyber Security – Information Protection)
• CIP-013-3 (Cyber Security – Supply Chain Risk Management)

NERC stated in its filings that the current versions of these standards prevent entities from taking advantage of security advances made possible by virtualization techniques. The new versions of these standards will allow entities to adapt to emerging risks with forward-looking security models. The NOPRs are available here: CIP-003-11 (Cyber Security – Security management Controls) NOPR, NOPR on Virtualization Reliability Standards.

U.S. House of Representatives passes GRID Power Act

The U.S. House of Representatives passed the GRID Power Act (H.R. 1047) on Sept. 18. The legislation would direct FERC to initiate a rulemaking to reform interconnection request procedures to “ensure that new dispatchable power projects that improve grid reliability and resource adequacy can interconnect to the electric grid quickly, cost-effectively, and reliably.”

The bill would also require FERC to update its Large Generator Interconnection Procedures and Agreements to allow transmission providers to submit proposals to FERC to prioritize dispatchable power projects in their queues. These proposals would demonstrate the need for the prioritization and how it would support grid reliability.

The bill would also require public comment and stakeholder engagement before proposals are submitted to FERC and would require FERC to approve or deny the proposals within 60 days of their submission. There is also a companion bill in the U.S. Senate that must be passed, and President Trump must sign before the bill becomes law.

U.S. House of Representatives introduces State Energy Accountability Act

A new House bill called the State Energy Accountability Act (H.R. 3157) would, if passed, amend the Public Utility Regulatory Policies Act (PURPA) to require any state regulatory authority that implements an intermittent energy policy to conduct and publicly release an evaluation of that policy’s effects. The evaluation must assess:

• The effects of implementing the policy on the reliability of the Bulk Power System in the State, including an assessment of the adequacy of available electric energy resources over a 10-year period
• The ability of intermittent resources to meet demand during emergencies, high demand periods, and extreme weather
• The effects on electric utility rates
• Whether reliable generation facilities removed from service to comply with the policy can be replaced with resources of equivalent accredited capacity
• The extent to which utilities must rely on out-of-state generation to maintain reliability

The bill says that states would “determine whether to adopt this standard” within one year of enactment and then publish the public evaluations within one year of that determination or the state’s adoption of an intermittent energy policy.

The post Regulatory Affairs news highlights: October 2025 appeared first on ReliabilityFirst.

State Energy Insights: October 2025

Grid Reliability and Regulatory Updates from ReliabilityFirst

News & Updates

RF shares analysis of August 2025 Baltimore load shed event

ReliabilityFirst (RF) on Tuesday published the August 2025 Baltimore Load Shed Event ReliabilityFirst After Action Analysis. The report details and analyzes the Aug. 11, 2025 bulk power system disturbance that impacted approximately 4,000 customers in the Baltimore area for a duration of 28 minutes.

Click here to read more

FERC to hold annual Reliability Technical Conference

FERC will hold its annual Reliability Technical Conference on Oct. 21 from 9:30 a.m. -12:30 p.m. ET.  The event will take place at FERC’s headquarters in Washington, D.C. and will also be live-streamed on the FERC website.

The event will open with a presentation from NERC President & CEO Jim Robb on the State of Reliability and will then feature two panel discussions.

During the first panel, “Leadership Perspectives on the State of the Bulk-Power System,” industry leaders will discuss key risks facing the grid and strategies to address these risks.

The second panel, “Ensuring Reliability with Large Loads,” will go into detail on how large loads can affect reliability and how utilities, grid planners, and regulators can best address this emerging risk. The full agenda is available here.

Federal and State Current Issues Collaborative to discuss energy permitting

FERC has announced that the next meeting of the Federal and State Current Issues Collaborative will take place on Wednesday, Nov. 12, from 8:30-10:30 a.m. PST in Seattle and via webcast.

The topic of the meeting will be energy infrastructure permitting, and a more detailed agenda will be released later this month. The collaborative was created by FERC and the state public utility commissions across the country to discuss and explore cross-jurisdictional issues of interest.

U.S. House of Representatives passes GRID Power Act

On Sept. 18 the U.S. House of Representatives passed the GRID Power Act (H.R. 1047), which would direct FERC to initiate a rulemaking to reform interconnection request procedures to “ensure that new dispatchable power projects that improve grid reliability and resource adequacy can interconnect to the electric grid quickly, cost-effectively, and reliably.”

The bill would also require FERC to update its Large Generator Interconnection Procedures and Agreements to allow transmission providers to submit proposals to FERC to prioritize dispatchable power projects in their queues. These proposals would demonstrate the need for the prioritization and how it would support grid reliability.

The bill would also require public comment and stakeholder engagement before proposals are submitted to FERC and would require FERC to approve or deny the proposals within 60 days of their submission. The bill now goes to the Senate for review.

U.S. House of Representatives introduces State Energy Accountability Act

A new House bill called the State Energy Accountability Act (H.R. 3157) would, if passed, amend the Public Utility Regulatory Policies Act (PURPA) to require any state regulatory authority that implements an intermittent energy policy to conduct and publicly release an evaluation of that policy’s effects.

The evaluation must assess:

• The effects of implementing the policy on the reliability of the Bulk Power System in the State, including an assessment of the adequacy of available electric energy resources over a 10-year period
• The ability of intermittent resources to meet demand during emergencies, high demand periods, and extreme weather
• The effects on electric utility rates
• Whether reliable generation facilities removed from service to comply with the policy can be replaced with resources of equivalent accredited capacity
• The extent to which utilities must rely on out-of-state generation to maintain reliability

The bill says that States would “determine whether to adopt this standard” within one year of enactment and then publish the public evaluations within one year of that determination or the state’s adoption of an intermittent energy policy.

U.S. Senate Confirms Laura Swett, David LaCerte as FERC Commissioners

Last week the U.S. Senate confirmed Laura Swett and David LaCerte to serve as commissioners at FERC.

Ms. Swett has served as an energy regulatory attorney at Vinson & Elkins, and at FERC in the Office of Enforcement and as advisor to past FERC commissioners.

Mr. LaCerte has served as White House liaison and senior adviser to the director of the Office of Personnel Management. Previously, Mr. LaCerte served in the first Trump administration and held legal positions at private firms, the Louisiana Department of Veterans Affairs, and the U.S. Chemical Safety and Hazard Investigation Board.

The commissioners were confirmed on a (51-47) party line vote. The confirmations will bring FERC to a 3-2 Republican majority.

Upcoming Events

Oct. 20, 2-3:30 p.m. ET | Tech Talk with RF

Coming up on the October edition of Tech Talk with RF, we’re focusing on cyber security for National Cyber Security Awareness Month.

Here’s what’s on the agenda:

• How to address the risk of insufficient trained OT cyber security personnel
  Mike Holcomb, Fellow, Director – ICS/OT Cybersecurity, Fluor
• ICS security without the guesswork: a risk-first approach 
  Stacy Bresler, Managing Partner, Archer Energy Solutions
• CIP standards update
  Lew Folkerth, Principal Reliability Consultant, External Affairs, RF 

Event details

The post State Energy Insights from ReliabilityFirst: October 2025 appeared first on ReliabilityFirst.

ReliabilityFirst (RF) on Tuesday published the August 2025 Baltimore Load Shed Event ReliabilityFirst After Action Analysis. The report details and analyzes the August 11, 2025 bulk power system disturbance that impacted approximately 4,000 customers in the Baltimore area for a duration of 28 minutes.

The disturbance stemmed from an unplanned outage at Baltimore Gas and Electric Company’s (BGE) Brandon Shores substation, located about 8 miles southeast of Baltimore. The event, triggered by multiple failed contaminated insulators, led to the loss of the entire 230 kV substation, cutting off all transmission paths from the station to the grid in an already resource constrained area. As the situation progressed, BGE and PJM Interconnection (PJM) responded using established escalating emergency procedures, including demand response, public conservation appeals, and voltage reduction to keep the system within safe operating limits.

Even with those measures, real-time engineering studies showed the potential of a cascading outage that could have impacted the entire city of Baltimore. Consequently, to ensure the transmission system stayed reliable and intact, PJM and BGE system operators shed approximately 20 MW of load, impacting 4,000 customers.

While disruption of customer electric supply is never a desired outcome, the actions taken by PJM and BGE preserved the system’s integrity. RF’s analysis indicates that the manual load shed mitigated a potential uncontrolled loss of more than 1,500 MW of load in the Baltimore area. Since the event, BGE has replaced numerous insulators and increased equipment inspections.

RF’s independent analysis showed that availability of local resources, including retired generation, would have helped to reduce the likelihood of load shedding during the event, despite transmission overloads, not resource shortfalls, driving the need to shed load. The full report incorporates critical data and a sequence of events provided by the impacted entities and includes RF’s independent analysis, technical findings, and evaluation of the sequence of events. For any questions about this report, please contact Communications@RFirst.org.

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ReliabilityFirst is one of six regional organizations which, in conjunction with the North American Electric Reliability Corporation (NERC), are known as the Electric Reliability Organization (ERO) Enterprise, responsible for ensuring the reliability and security of the North American Bulk Electric System. We promote the reliability and security of the electric grid through standards, outreach, training and analysis, that includes partnership with communities and experts. We are based out of Cleveland, Ohio, and our footprint includes the Great Lakes and Mid-Atlantic areas of the United States.  

The post RF shares analysis of August 2025 Baltimore load shed event appeared first on ReliabilityFirst.

State Energy Insights: September 2025

Grid Reliability and Regulatory Updates from ReliabilityFirst

News & Updates

FERC Chairman David Rosner speaks with NERC President and CEO Jim Robb on stage at RF’s Fall Reliability and Security Summit in Oxon Hill, Maryland, on Sept. 9, 2025.

RF brings together key energy industry players, including FERC chairman, for Reliability & Security Summit

RF hosted its 2025 Fall Reliability & Security Summit last week in the Washington, D.C., area. This event brought together key players from across the energy industry, including more than 200 people in person across the three-day event, and more than 150 people for a portion of the event that was livestreamed virtually.

Throughout the summit, the focus of the programming centered on maintaining and improving the reliability and security of the electric grid. We were thrilled to host an incredible lineup of speakers who shared their valuable insights with our audience, including newly appointed FERC Chairman David Rosner, who sat down for a “fireside chat” with NERC President and CEO Jim Robb. Attendees also took in a riveting panel discussion featuring PPL Electric Utilities President Christine Martin, AEP President and CEO Bill Fehrman, Electric Power Supply Association President and CEO Todd Snitchler, and FERC Office of Energy Infrastructure Security Director Joe McClelland.

To see more highlights from this event, check out our LinkedIn feed.

RF to discuss reliability impact of recent federal actions at upcoming OPSI meeting

RF Manager of Regulatory and Legislative Affairs Michelle Cross will join a panel discussion focused on the impact of executive orders, Department of Energy actions, and changes in federal law on wholesale electric markets at the annual meeting of the Organization of PJM States, Inc. (OPSI) on Oct. 6-7 in Washington, D.C.

RF’s role in the discussion will be a focus on maintaining grid reliability and security while navigating policy decisions.

More information on this event is available here.

NERC Large Loads Task Force releases white paper on characteristics and risks of emerging large loads

As emerging large loads seek to swiftly interconnect to the grid, they pose new risks. NERC’s Large Load Task Force analyzes the reliability impacts related to emerging large loads (such as AI data centers, industrial facilities, and hydrogen production facilities). The task force’s recent white paper characterizes large loads and defines the reliability risks that they may pose to the Bulk Power System. The white paper is available here.

Cybersecurity and Infrastructure Security Agency (CISA) releases advisory on threat actors from China, recommendations to mitigate risk

Earlier this month, CISA (in partnership with other agencies such as the NSA and FBI and international agency partners) released a Joint Cybersecurity Advisory on state-sponsored Advanced Persistent Threat (APT) actors from China that are “targeting critical infrastructure across sectors and continents to maintain persistent, long-term access to networks” for use in global espionage.

The advisory states that multiple investigations have shown that these actors are exploiting vulnerabilities in the routers of telecommunications providers to gain and maintain access, particularly in telecommunications, government, transportation, lodging, and defense networks. The advisory also contains recommended actions and mitigations to help address the threat.

Upcoming Events

Oct. 20, 2-3:30 p.m. ET | Tech Talk with RF

Coming up on the October edition of Tech Talk with RF, we’re focusing on cyber security for National Cyber Security Awareness Month.

We are still finalizing the agenda. Stay tuned for more details on our LinkedIn feed and website!

Event details

The post State Energy Insights from ReliabilityFirst: September 2025 appeared first on ReliabilityFirst.

First Things RFirst: August 2025

Expert analysis for a more reliable, secure and resilient electric grid, plus news and updates for RF stakeholders.

Insights & Analysis

Enforcement Explained: Trends in vegetation management

Learn about recent trends in vegetation management and FAC-003 (Transmission Vegetation Management) violations specifically in the latest edition of Enforcement Explained. This topic is especially relevant on the Aug. 14 anniversary of 2003 Northeast Blackout, as ineffective vegetation management (specifically a failure to adequately manage tree growth within transmission rights-of-way) was a key cause of the blackout.

Click here to read more

Regulatory Affairs: Grid reliability news we’re tracking

The latest regulatory headlines we’re tracking include:

• President Trump nominates David LaCerte to serve as FERC commissioner
• FERC Chair Mark Christie holds last open meeting before leaving commission
• DOE releases report on grid reliability and security
• CISA, FBI, NSA, and Department of Defense issue fact sheet on cyber threats from Iran

Click here to read more

News & Updates

FERC issues Order 909 approving new IBR standards

On July 24, FERC issued Order 909 – Reliability Standards for Frequency and Voltage Protection Settings and Ride-through for Inverter-Based Resources (IBRs), which establishes new ride-through performance requirements to mitigate reliability concerns with IBR tripping and momentary cessation.

FERC recognized the need for these protections in Order 901, where it states that “as found by multiple NERC reports, some IBRs are not configured or programmed to support grid voltage and frequency in the event of a system disturbance, and…will reduce power output, exhibit momentary cessation, or trip in response to variations in system voltage or frequency.”

In Order 909, FERC approves PRC-024-4 (Frequency and Voltage Protection Settings for Synchronous Generators, Type 1 and Type 2 Wind Resources, and Synchronous Condensers), PRC-029-1 (Frequency and Voltage Ride-through Requirements for Inverter-Based Resources), and a definition of the term “ride-through” to mean “the plant/facility remains connected and continues to operate through voltage or frequency system disturbances.”

PRC-024-4 removes language that was in PRC-024-3, R1 through R4 on IBR functionality that are now included in PRC-029-1. PRC-029-1 establishes frequency and voltage ride-through performance requirements and criteria for generator owners of IBRs. Specifically, PRC-029-1, R1-R3 establishes requirements to address abnormal IBR tripping, interruption of current injection, and reduced power output, and R4 sets out a process for generator owners to seek an exemption to R1-R3 for hardware limitations.

While FERC approves PRC-029-1 in Order 909, it also directs NERC to determine through its standards process whether and how to account for equipment limitations of HVDC-connected IBRs with choppers (which may physically prevent them from fully complying with the ride-through provisions of the standard), and the long lead time between adopting IBR design specifications and placing the IBR in service. NERC also must submit an informational filing to FERC in 18 months on the reliability impacts of the PRC-029-1, R4 exemption process (including how many exemptions were requested and granted and the reasons for the exemptions).

In Order 909 FERC also encourages NERC and the Regional Entities to “use their available tools – appropriate enforcement discretion, targeted oversight activities, compliance and enforcement guidance, and the compliance feedback loop to standards development – to ensure consistency, reasonably address noncompliance that does not impact reliability, and to identify, assess, and implement any need for additional improvements to the Standard through its approved processes.”

RF hosts Protection System and Human Performance Workshops

ReliabilityFirst hosted our 11th Annual Protection System Workshop on Aug. 6 and our 8th Annual Human Performance Workshop on Aug. 7.

The Protection System Workshop drew 250 virtual attendees and the Human Performance workshop saw 200 participants log on and attend.

These events provided an opportunity for registered entity personnel to interact with their counterparts by asking questions, learning new techniques and procedures, and sharing their real-life experiences.

If you have questions, need more information, have topic suggestions, or would like to present at future workshops, please contact our Engineering & System Performance department via the dropdown on our website here.

ReliabilityFirst Board of Directors elects two new members, and re-elects one director

The ReliabilityFirst Board of Directors elected two new directors and re-elected one current director on Aug. 1.

Robert Bradish was elected to represent the Supplier Sector, with his term set to run through December 2026. He is currently Chief Transmission Officer at AEP Transmission.

Mark Mroczynski was elected to represent the Transmission Sector, with his term set to run through December 2027. He is currently President of Transmission for FirstEnergy.

Bradish and Mroczynski will begin their terms immediately.

Medium LSE Sector Director Steve Ambrose, whose term was set to expire this year, was re-elected. His term will now run through 2028.

More information on each of these directors is included in their bios on our Board of Directors page.

Upcoming Events

Aug. 18, 2- 3:30 p.m. ET | Tech Talk with RF

Coming up on the August edition of Tech Talk with RF, we’re focusing on inverter-based resources (IBRs).

We will have a presentation on what to know about NERC Reliability Standard PRC-029-1 and how it will impact IBRs.

Then we will also have a presentation on Rate of Change of Frequency as it relates to underfrequency load shedding. With the ever-increasing mix of IBRs powering the electric grid, this relationship has gained importance, as system inertia decreases.

Event details

Sept. 8-10, 2025 | RF Fall Reliability & Security Summit

Register now for RF’s Fall Reliability & Security Summit. This year’s event will be hosted at the MGM National Harbor just outside of Washington, D.C.

Be sure to make your hotel reservation now to secure our discounted room block rate! This deadline has been extended to Monday, Aug. 18, but time is running out!

We’ll kick things off at the summit with an evening reception and our Reliability Recognition Awards Ceremony on Monday, Sept. 8.

Then, we have an exciting agenda on Tuesday, Sept. 9, where we’ll be joined by key players from across the electric industry, including:

• FERC Commissioner David Rosner
• NERC President & CEO Jim Robb
• RF President & CEO Tim Gallagher
• FERC Director of Office of Energy Infrastructure Security Joe McClelland
• AEP President & CEO Bill Fehrman
• LS Power CEO Paul Segal
• PPL Electric Utilities President Christine Martin
• Electric Power Supply Association President & CEO Todd Snitchler
• And more!

Finally, on Wednesday, Sept. 10, attendees will be able to choose from three half-day tracks, depending on which focus area makes the most sense for them. These include an energy policy leadership session, an internal controls workshop for experienced registered entity personnel, and a NERC 101 primer for new registered entities.

The full agenda and registration link are available on our website. We hope to see you there!

Event details

Nov. 18-19, 2025 | GridEx VIII

GridEx is the largest grid security exercise in North America, hosted every two years by the NERC Electricity Information Sharing and Analysis Center (E-ISAC). It offers E-ISAC member and partner organizations a forum in which to practice how they would respond to and recover from coordinated cyber and physical security threats and incidents.

The last event in 2023 saw more than 15,000 participants come together from approximately 250 North American organizations, including the electric industry, cross-sector partners from gas and telecommunications, and U.S. and Canadian government partners.

Event details

To explore our full calendar of upcoming events, click here.

The post First Things RFirst: August 2025 appeared first on ReliabilityFirst.

Recent regulatory headlines we’re tracking include:

President Trump nominates David LaCerte to serve as FERC commissioner

President Donald Trump has nominated David LaCerte to serve as a FERC commissioner in the seat vacated by Willie Phillips’ resignation in April 2025. LaCerte would serve the remainder of former Chair Phillips’ term until June 30, 2026.

Currently, he serves as White House liaison and senior adviser to the director of the Office of Personnel Management. Previously, LaCerte served in the first Trump administration and held legal positions at private firms, the Louisiana Department of Veterans Affairs, and the U.S. Chemical Safety and Hazard Investigation Board.

FERC Chair Mark Christie holds last open meeting before leaving commission

On July 24, FERC Chair Mark Christie participated in his last open FERC meeting before stepping down from the position. In early June, President Trump nominated Laura Swett, an energy regulatory attorney at Vinson & Elkins and former FERC attorney, to take Christie’s seat at FERC.

Christie provided remarks during the open meeting reflecting on his career in the energy industry and thanking his staff and fellow FERC commissioners. He also shared his thoughts on the importance of consumers and electricity prices.  He stated, “I hope that everybody who ever sits on this Commission always remembers those people’s wishes — the millions of people who pay the bills, struggle and worry about whether their lights come on or not.” A link to the webcast of this FERC meeting is available here.

DOE releases report on grid reliability and security

In early July, the Department of Energy (DOE) released its Report on Evaluating U.S. Grid Reliability and Security. The report warns of increasing power outages due to a growing mismatch between electricity demand and supply that is driven by retirements of fossil fueled generation, insufficient additions of new firm capacity, and load growth driven by data centers. This report is a response to President Trump’s executive order from April, which directed the DOE to create a uniform method of studying resource adequacy.

The report argues for “decisive intervention” to prevent the projected increase in power outages in the 2030s. The report uses a model based on NERC’s Interregional Transfer Capability Study, which uses time-correlated generation and outages based on historical data, and the model found the greatest projected shortfalls to be in PJM and ERCOT. Critics of the report argue that it exaggerates the risk of blackouts and undervalues the reliability contributions of wind, solar, and battery storage.

CISA, FBI, NSA, and Department of Defense issue fact sheet on cyber threats from Iran

On June 30, CISA, the FBI, the Department of Defense Cyber Crime Center (DC3), and the National Security Agency (NSA) published a new fact sheet titled Iranian Cyber Actors May Target Vulnerable US Networks and Entities of Interest. The document discusses the increased geopolitical threat and need for increased vigilance for potential cyber activity against U.S. critical infrastructure by Iranian state-sponsored or affiliated threat actors. In an accompanying notice, the agencies state that they have not seen indications of a coordinated campaign of malicious cyber activity in the U.S. that can be attributed to Iran, but they stress that despite reports of a ceasefire, owners and operators of critical infrastructure organizations and other potentially targeted entities should review the fact sheet to learn more about the Iranian state-backed cyber threat and recommended mitigations to harden cyber defenses.

The fact sheet states that Iranian-affiliated cyber actors often exploit targets of opportunity based on the use of unpatched or outdated software with known Common Vulnerabilities and Exposures (CVEs) or the use of default or common passwords on internet-connected accounts and devices. It also describes previous Iranian cyber campaigns, provides a list of recommended mitigation actions, and a list of resources on the Iranian threat and best practices in cyber security. The fact sheet is available here.

The post Regulatory Affairs news highlights: August 2025 appeared first on ReliabilityFirst.