On December 20, 2022, NEPGA, EPSA and P3 (the Competitive Generators) jointly filed an Answer to comments filed by the ISO/RTO Council in the FERC proceeding concerning new generator freeze protection standards proposed by the North American Electric Reliability Organization (NERC) (Docket No. RD23-1-000). On October 28, 2022, NERC filed for FERC approval a set of new reliability standards requiring both new and existing generators to adopt freeze protection measures under certain cold weather conditions. On December 8, NEPGA and several other parties filed comments, including the ISO/RTO Council which asks FERC to both approve the reliability standards as filed by NERC and to direct NERC to make certain changes to its proposal (with a compliance filing due November 2023), including a material change to the definition of the key variable driving obligations and actions under the proposed standards – the so-called Extreme Cold Weather Temperature. In their Answer, the Competitive Generators explain that to grant the ISO/RTO request for relief would create the risk that generator actions taken to comply with the standards as filed by NERC would prove futile if a materially different (and more difficult to meet) standard were to take effect relatively soon thereafter. The Competitive Generators also repeat their call (from their initial comments) for FERC to direct ISO/RTOs to timely develop market designs or mechanisms to allow generators to recover the costs of complying with the freeze protection standards, explaining in part that cost recovery certainty would hedge the risk of taking actions and incurring costs that may later prove insufficient to meet any revised standard approved by FERC.