COVID-19 and the Power Sector

Update 5/22/2020

As of today, 7 of New York State's 10 regions have begun Phase 1 of reopening, as shown on the State's NY Forward dashboard. Governor Cuomo announced at today's press briefing that the Long Island and Mid-Hudson regions can begin reopening next week.

Phase 1 of reopening allows for construction to resume, which impacts energy projects. NYSERDA has posted guidance on resuming construction activities, which you can view here. More from the State on the phases of reopening can be found here.


We at IPPNY hope that you, your family, and your company are remaining safe and healthy. We feel it is our responsibility to help provide information that may be useful to your companies as you develop strategies and contingencies for dealing with the impact of COVID-19 (coronavirus) on your businesses and the power sector at large. Each of your companies plays a critical and indispensable role in maintaining electric system reliability, which is why we hope our services can assist you in navigating this period of great uncertainty.

New York State Governor Andrew Cuomo has taken a variety of actions to limit the spread of COVID-19. IPPNY issued a series of Member Alerts (Numbers 15, 16, 17, 18, 19, 22, 25, 26) covering how the power sector has been impacted by the response to COVID-19 and, importantly, underscoring that essential exempted industries from workforce restrictions continue to include the power generation and utility sectors.

The Governor has required that 100% of the workforce of all non-essential businesses work from home with Executive Order 202.8. Under the New York State on PAUSE plan, which is in place until May 15, all non-essential businesses statewide must implement work from home policies or be closed. Guidance and further information on these restrictions can be found from the New York State Department of Health and Empire State Development Corporation.

On the issue of essential construction, the Empire State Development Corporation has defined which power generation projects currently under construction are exempt as essential infrastructure services under the Governor's Executive Order. In the ESD's Frequently Asked Questions document, linked here, Question 14 addresses this topic.

IPPNY MOU with NYPA and National Grid

The most notable development to date is that IPPNY, on behalf of its Members, has jointly signed a Memorandum of Understanding ('MOU") with NYPA and National Grid that mutually commits all signatories to consider requests for assistance at their facilities, such as deployment of trained personnel to work on site at the requesting party's facilities, including in sequestration-in-place environments, in light of the possibility that COVID-19-related illnesses may disrupt various aspects of the provision of critical reliability services at their facilities. The MOU is a commitment by the signatories to enter into agreements, upon requests, to make available the resources necessary to ensure that the provision of reliable electric service is able to be maintained at all critical operating facilities for as long as COVID-19 disrupts normal operations.

IPPNY's signature does not obligate individual IPPNY Member companies to provide assistance, but it does commit IPPNY to help facilitate the development of mutual assistance agreements by coordinating communication between IPPNY's Member companies and the signatories to the MOU, as well as among themselves. Such assistance may also include forms of support services, equipment, materials, supplies, and fuels. IPPNY Members would enter into such arrangements entirely at their own discretion and after taking into account their own operational needs, the health and safety of their own workers, and any other circumstances.

What the NYISO is Doing

NYISO and NYC officials have recommended that essential employees, such as plant operators, carry with them at all times accurate company identification and a letter from their corporate office identifying them as an essential/critical employee. In addition, it is recommended that companies have in place a process for law enforcement to contact plant management to confirm employee necessity. The NYISO has made it clear that, if travel restrictions are put in place and exemptions are needed in order to travel, the NYISO would emphatically support the position that generator staffs across the state, but particularly in NYC and Long Island, are crucial to maintaining electric system reliability.

The NYISO has and continues to be in direct contact with generation owners, the local transmission owners, and state officials, including the Governor's Office, the PSC, and NYC, to gauge preparedness, and it has taken the following actions to maintain critical business operations and protect the health and well-being of its employees and stakeholders:

  • The NYISO has fully sequestered its control room operators. The NYISO currently has sheltered in place teams of 30 grid operators at two control centers with sleeping quarters, facilities personnel, and food services. There is a rotation in place to maintain grid operations under this setup for the foreseeable future.
  • The NYISO has also implemented a rotational work-from-home schedule to reduce employee exposure to the virus, while maintaining business operations;

  • Protocols have been put in place to minimize grid operator exposure to infection and to ensure that adequate staff with the necessary technical expertise is available in the event that some portion of the operations crew is unable to report due to infection;

  • Stakeholder meetings are being conducted via teleconference for the foreseeable future;

  • Internal meetings are being conducted via teleconference, and in-person meetings have been reduced to essential personnel only and will follow social distancing protocols;

  • All business travel is suspended;

  • Outside visitors are restricted to those critical to ensuring business continuity;

  • Individual employee health is being monitored on a daily basis; and

  • Additional protocols for office sanitation, social distancing, hand washing and other Center for Disease Control and Prevention protocols are being followed.

The NYISO has reported that the local transmission owners have taken similar actions at their control centers, including the ability to quarantine grid operators onsite, if necessary.

Also of note - NYPA too has sequestered its control room personnel through coordination with union leaders. Non-control room personnel are being tested upon entering individual facilities according to wellness check procedures. NYPA is also following protocols related to cyber security, which is of heightened concern due to most employees working remotely via telecommunication services.

Power Plant Sequestration

IPPNY has received multiple questions from Members asking whether the NYISO or NYS will require that generators sequester their staffs. At this time, the NYISO, NYPA, and the New York Transmission Owners have sequestered employees at their control centers and power plants, but there remains no requirement for generation owners to do the same, nor is IPPNY aware of any intentions to require such action or generators who have executed their sequestration plans. While it remains highly encouraged that generators have in place sequestration plans, decisions to activate said plans remain a company to company decision.

For power plant operators:

1. Electric Subsector Coordinating Council (ESCC) Resource Guide - A resource to guide informed localized decisions in response to COVID-19. It highlights data points, stakeholders, and options to consider in making decisions about operational status, while protecting the health and safety of employees, customers, and communities. 
2. U.S. Department of Energy COVID-19 Frequently Asked Questions - A resource that includes information on the DOE's response to COVID-19 with links to other important sites.
3. NYPA's Wellness Check Procedure - Items 3-7 detail NYPA's process for assessing the wellbeing of employees, how to handle potential symptomatic workers, and their sequestration process. These have been provided as a template for others to follow.
8. NYPA Cyber Security Actions - a document describing cyber security actions taken by NYPA.
9. Electric Power Research Institute Presentation - A slide deck looking at demand impacts and operational and control center practices during the COVID-19 outbreak.
10. U.S. Dept. Homeland Security Cyber Infrastructure Risk Management for Coronavirus - This document is for executives to help them think through physical, supply chain, and cybersecurity issues that may arise from the spread of COVID-19.

Who to Contact

Please reach out to IPPNY for contact information for PSC, NYC, and NYISO officials. For the PSC and NYC, we've been asked that questions be funneled through IPPNY unless there is an emergency, such as the need to notify the state/city of critical supply delivery issues or to seek assistance in communicating to proper state authorities. It has been requested that generators, or representatives of generators, do not call the Governor's Office directly, as it is using up critical resources during this time. We've been asked that all requests, instead, be funneled through the PSC, IPPNY, or another appropriate authority. Questions regarding operating procedures and issues should be directed to the NYISO.

Federal Action

At the federal level, FERC and NERC have announced that they are taking steps to ensure that operators of the bulk electric system can focus their resources on keeping people safe and the lights on. According to the press release, FERC and NERC outlined that they are using regulatory discretion to advise all registered entities that they will consider the impact of the coronavirus outbreak in complying with Reliability Standards as follows:

  • The effects of the coronavirus will be considered an acceptable basis for non-compliance with obtaining and maintaining personnel certification, as required in Reliability Standard PER-003-2, for the period of March 1, 2020 to December 31, 2020. Registered entities should notify their Regional Entities and Reliability Coordinators, when using system operator personnel that are not NERC-certified.

  • The effects of the coronavirus will be considered an acceptable reason for case-by-case non-compliance with Reliability Standard requirements involving periodic actions that would have been taken between March 1, 2020 and July 31, 2020. Registered entities should notify their Regional Entities of any periodic actions that will be missed during this period.

  • Regional Entities will postpone on-site audits, certifications and other on-site activities at least until July 31, 2020. Registered entities should communicate any resource impacts associated with remote activities to their Regional Entities.

FERC and NERC will continue to evaluate the situation to determine whether to extend the dates.

Also, the Electric Subsector Coordinating Council ("ESSC"), which is a CEO-led association of 20 investor-owned utilities and public power authorities, is meeting regularly to address concerns and coordinate planning with respect to five key areas: (1) control center continuity; (2) accessing quarantines and restricted environments; (3) maintaining availability of personal protection equipment for essential personnel; (4) facility preparedness; and (5) generation operational continuity. ESSC is also focusing on telecommunications.

IPPNY is in continued communication with its regional partners on these issues, in particular the Electric Power Supply Association ("EPSA"). EPSA is participating in regular COVID-19-related meetings of the Electricity Subsector Coordinating Council, which is a CEO-led organization that acts as the principal liaison between the Federal Government and the electric power industry. The Council's mission is coordinating efforts to prepare for, and respond to, national-level disasters or threats to critical infrastructure. IPPNY will continue to update Members as appropriate.