Extreme Weather Response Risk Element

The Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan (IP) annually highlights the risk elements marked for oversight prioritization during a given year. One such risk element in the 2025 CMEP IP is extreme weather response.

Extreme weather events encompass a wide range of situations that can cause major Bulk Electric System (BES) impacts. There were several notable extreme weather events in 2024 that impacted Texas, including a geomagnetic storm and Hurricane Beryl. Prior to 2024, a significant number of entities experienced outages and derates at facilities during Winter Storms Uri and Elliot, raising concerns for blackstart unit readiness. Inverter-based resources (IBRs) continue to grow as a portion of the generation resource mix but few of those on the system are capable of grid forming control, one of the necessary components for blackstart resources.

Registered entities with applicable BES Cyber Systems (BCS) should expect to see EOP-011-4 and EOP-012-2 in their 2025 engagement scopes (if those Standards are applicable and have not been included in a recent engagement). The Texas RE engagement team will look at preventive, detective, and corrective controls that an entity uses to mitigate overall risks, in addition to evaluating compliance. Texas RE’s engagement observations may be reflected in an entity’s next Compliance Oversight Plan (COP).

For extreme weather response risks, entities should consider these questions around controls:

1. EOP-011-4 R1
   1. What controls do you have in place to ensure that internal and external contact lists are up to date and available during emergency conditions?
   2. What controls ensure that your Operating Plan(s) has provisions to determine the reliability impacts of extreme weather conditions?
2. EOP-012-2 R4, R5
   1. How do you ensure all applicable contractors, operators, maintenance, and associated support personnel receive winter-specific and plant-specific training for implementing cold weather preparedness plans?
   2. How do you ensure winterization supplies and equipment are in place before the winter season?

The Engagement Common Questions document also provides insights on areas Texas RE auditors could focus on during an engagement. Please contact information@texasre.org with any questions.