Attention Renewable Owners and Operators – Do You Know NERC?

NERC serves as the nation’s electric reliability watchdog, with compliance enforcement authority from FERC. NERC is expanding its compliance reach to smaller renewable generators that were previously excluded from registration criteria by modifying its rules of procedure.

In November of 2022, the Federal Energy Regulatory Commission (FERC) issued an order that directed the North American Reliability Corporation (NERC) to submit a work plan describing how it planned to identify and register owners and operators of inverter-based resources (IBRs)^[1] that are connected to the bulk power system (BPS) but are not currently required to register under NERC’s Bulk Electric System (BES) definition exclusions.  The basis for this expansion is that, in aggregate, these unregistered facilities may have a material impact on the reliable operation of the overall BPS which includes all parts of the grid regardless of generator size and voltage levels.

The work plan was approved in May of 2023 and includes revisions to NERC’s Rules of Procedure (ROP) to address registration of owners and operators of unregistered IBRs that could have an aggregate, material impact on reliability. NERC determined that the creation of two new functional categories (GO-IBR and GOP-IBR) in the ROPs was more efficient than incorporating unregistered IBRs into the existing Generator Owner (GO) and Generator Operator (GOP) functional definitions or revising NERC’s Bulk Electric System definition. 

These revisions propose to register owners and operators of IBRs that have an aggregate nameplate capacity of greater than or equal to 20 MVA, delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV (there are no plans to revise Registry Criteria in relation to owners/operators of transmission lines under 100 kV at this time). Owners and operators of IBRs greater than 75 MVA connected at 100 kV and above are already subject to registration under the existing GO/GOP ROP Registry Criteria. 

NERC has provided detailed background materials for stakeholders that may not be familiar with the NERC community (linked below) as well as guidance on mitigating IBR^[2] performance risks associated with BPS operations.  As we move into 2024, NERC will be working through its Regional Entities (SERC, NPCC, WECC, RF, MRO, TRE depending on geographic location of the site) as well as trade organizations and other avenues to inform and guide potential candidates through the registration^[3] process.  NERC’s tentative timeline is excerpted below.

Once the registration process is underway, subsequent NERC reliability standards revisions, developed through NERC’s standards development process, will be required to identify which standards/requirements should be applicable to the newly registered GO-IBRs and GOP-IBRs.  The “applicability” of various existing standards will be revised to include GO-IBR/GOP-IBR entities as deemed appropriate through industry consensus.

Whether you are an existing client or just curious, NEI stands ready to provide the support and services that may be needed to ensure your renewable generation facility can demonstrate compliance to existing GO/GOP or future GO-IBR/GOP-IBR reliability standard requirements. 

For additional information and resources, visit these links:

[1] 2023 NERC Guide: Inverter Based Resources (nerc.com)
[2] Quick Reference Guide: IBR Activities (nerc.com)
[3] Quick Reference Guide: Candidate for Registration, September 2023 (nerc.com)