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Infrastructure 5 min read Published Updated Credibility 90/100

Infrastructure Resilience Briefing — November 20, 2024

NERC's 2024–2025 Winter Reliability Assessment and FERC's market outlook demand stricter cold-weather preparedness and fuel assurance across North American grids.

Zeph Tech Research Lead

Research lead, Zeph Tech

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Executive briefing: NERC’s 2024–2025 Winter Reliability Assessment and FERC’s companion Winter Energy Market and Reliability Assessment (both released November 20, 2024) warn of elevated risk in MISO, SPP, ISO-NE, and Alberta due to gas deliverability constraints and extreme-weather uncertainty. Regulators mandate cold-weather readiness, fuel management, and coordination drills for generators and data-center operators relying on the bulk power system.

Key industry signals

  • Resource adequacy gaps. NERC identifies 5–8 GW reserve shortfalls during extreme cold snaps in MISO and SPP without load-shedding contingencies.
  • Gas supply strain. FERC flags pipeline maintenance and LNG exports as winter risk factors, urging firm transport contracts for critical load.
  • Operational mandates. NERC’s EOP-011-2 and cold-weather reliability standards become enforceable December 1, 2024, requiring documented winterization plans and performance testing.

Control alignment

  • NERC CIP/EOP. Update winterization procedures, generator fuel inventories, and black-start coordination to match the latest assessment findings.
  • Business continuity. Align ISO/IEC 22301 and ISO/IEC 27001 continuity clauses with NERC directives to evidence resilience posture during customer audits.

Detection and response priorities

  • Run joint exercises with utilities simulating fuel curtailment and system restoration; incorporate FERC-identified stress scenarios.
  • Monitor pipeline operator bulletins and natural gas balancing alerts daily during the winter peak season.

Enablement moves

  • Secure firm gas contracts or on-site storage for critical facilities located in highlighted risk zones.
  • Document compliance evidence for NERC’s cold-weather standards—testing records, staffing rosters, and communication protocols—for audit readiness.

Sources

Zeph Tech equips infrastructure leaders with regulator-sourced evidence to harden facilities before winter load peaks.

Operational monitoring

Operations teams should enhance monitoring and observability for infrastructure changes:

  • Metrics collection: Identify key performance indicators and operational metrics exposed by this component. Configure collection pipelines and retention policies appropriate for capacity planning and troubleshooting needs.
  • Alerting thresholds: Establish alerting rules that balance sensitivity with noise reduction. Start with conservative thresholds and tune based on operational experience to minimize false positives.
  • Dashboard updates: Create or update operational dashboards to provide visibility into component health, resource utilization, and dependency status. Ensure dashboards support both real-time monitoring and historical analysis.
  • Log aggregation: Configure log shipping, parsing, and indexing for relevant log streams. Define retention policies and implement log-based alerting for critical error conditions.
  • Distributed tracing: If applicable, integrate with distributed tracing systems to enable end-to-end request visibility and performance analysis across service boundaries.

Document monitoring configuration in version-controlled infrastructure-as-code to ensure reproducibility and facilitate disaster recovery scenarios.

Cost and resource management

Infrastructure teams should evaluate cost implications and optimize resource utilization:

  • Cost analysis: Assess the cost impact of infrastructure changes, including compute, storage, networking, and licensing. Model costs under different scaling scenarios and traffic patterns.
  • Resource optimization: Right-size resources based on actual utilization data. Implement auto-scaling policies that balance performance requirements with cost efficiency.
  • Reserved capacity planning: Evaluate opportunities for reserved instances, savings plans, or committed use discounts. Balance reservation commitments against flexibility requirements.
  • Cost allocation: Implement tagging strategies and cost allocation mechanisms to attribute expenses to appropriate business units or projects. Enable chargeback or showback reporting.
  • Budget management: Establish budget thresholds and alerting for infrastructure spending. Implement governance controls to prevent cost overruns from unauthorized provisioning.

Regular cost reviews help identify optimization opportunities and ensure infrastructure investments deliver appropriate business value.

Security and compliance

Infrastructure security teams should assess and address security implications of this change:

  • Network security: Review network segmentation, firewall rules, and access controls. Ensure traffic patterns align with security policies and zero-trust principles.
  • Identity and access: Evaluate authentication and authorization mechanisms for infrastructure components. Implement least-privilege access and rotate credentials regularly.
  • Encryption standards: Ensure data encryption at rest and in transit meets organizational and regulatory requirements. Manage encryption keys through appropriate key management services.
  • Compliance controls: Verify that infrastructure configurations align with relevant compliance frameworks (SOC 2, PCI-DSS, HIPAA). Document control implementations for audit evidence.
  • Vulnerability management: Integrate vulnerability scanning into deployment pipelines. Establish patching schedules and remediation SLAs for infrastructure components.

Security considerations should be integrated throughout the infrastructure lifecycle, from initial design through ongoing operations.

  • Recovery objectives: Define and validate Recovery Time Objectives (RTO) and Recovery Point Objectives (RPO) for affected systems. Ensure objectives align with business continuity requirements.
  • Backup strategies: Review backup configurations, schedules, and retention policies. Validate backup integrity through regular restoration tests and document recovery procedures.
  • Failover mechanisms: Test failover procedures for critical components. Ensure automated failover is properly configured and manual procedures are documented for scenarios requiring intervention.
  • Geographic redundancy: Evaluate multi-region or multi-datacenter deployment requirements. Implement data replication and synchronization appropriate for recovery objectives.
  • DR testing: Schedule regular disaster recovery exercises to validate procedures and identify gaps. Document lessons learned and update runbooks based on test results.

Disaster recovery preparedness is essential for maintaining business continuity and meeting organizational resilience requirements.

Infrastructure Assessment and Remediation

Infrastructure teams should conduct comprehensive assessments to identify affected systems and prioritize remediation based on exposure and criticality. Patch management processes should account for the specific technical requirements and potential compatibility considerations associated with this update. Testing procedures should validate that patches do not introduce operational disruptions before deployment to production environments.

Monitoring should continue post-remediation to verify successful implementation and detect any exploitation attempts targeting systems that remain vulnerable during the patching window.

Operational Considerations

Organizations should assess the operational implications of this development for their specific environment and circumstances. Implementation approaches should balance thoroughness with practical resource constraints and competing priorities. Phased implementations often provide better outcomes than attempting comprehensive changes simultaneously.

Cross-functional coordination ensures that technical changes align with business processes, compliance requirements, and risk management frameworks. Regular communication with stakeholders maintains alignment and identifies potential issues early in the implementation process.

Documentation should capture implementation decisions, configuration details, and operational procedures to support ongoing maintenance and future reference. Version control and change management practices help maintain consistency and enable rollback if issues arise.

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  • NERC
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  • Winter readiness
  • Fuel assurance
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