As many are aware, the growing number of inverter-based resources (IBRs) that are connected to the Bulk Power System (BPS) has created reliability concerns which prompted FERC to issue Order 901 in October 2023. FERC Order 901 directed NERC to update its Reliability Standards to include and address IBRs reliability risks in four main areas:

• Data Sharing
• Model Validation
• Planning and Operational Studies
• Performance Requirements

In response to FERC Order 901, NERC released a work plan in January 2024, that outlines the next steps in identifying and registering owners and operators of unregistered IBRs, addressing the main reliability risks, and implementation timelines. The plan involves revising NERC’s Registration Program to include new criteria for IBR owners and operators, ensuring compliance with applicable Reliability Standards.

The proposed revisions, detailed in NERC’s draft Rules of Procedure, aim to accommodate unregistered IBRs and establish Category 2 Generator Owners and Operators. More on Category 1 versus Category 2 below. Through a series of milestones, NERC plans to identify, assess, and register these generators to bolster grid reliability by early 2026. 

For those interested in participating in these discussions, here are the dates for the upcoming Compliance and Certification Committee (CCC) meetings in 2024:

• July 23-25: Folsom, CA (California ISO – CAISO)*
• October 15-17: Atlanta, GA (NERC Offices)

*GridSME will be attending the CCC meetings. If you plan to attend the July 23-25 meeting in Folsom, CA, we would love to host you in our office that week (July 23-235). Please reach out to srhodes@gridsme.com or bdgroup@gridsme.com for coordination.

This update is to provide owners and operators with a summary of the latest updates from NERC, as well as links to NERC resources and other helpful information. GridSME also aims to provide guidance on next steps, if any, for owners and operators to take and/or plan for in the coming months.

1) What does the timeline look like and when do I need to take action?

When first announced, NERC identified four (4) key milestones and approximate dates for deliverables, decisions, and implementation of the GO-IBR requirements. In addition to those milestones, there are three (3) Phases that Generator Owners (GO) and Generator Operators (GOP) need to be aware of:

Phase 1, which started in May 2023 and ended in May 2024 included:

• Complete Rules of Procedure revisions and approvals
• Commence Category 2 GO and GOP candidate outreach and education

Phase 2, which is the current state of the program, spans from May 2024 through May 2025. This Phase includes:

• Complete identification of Category 2 GO and GOP candidates
• NERC outreach and education to Category 2 GO and GOP candidates

Phase 3 is expected to begin in May 2025 and continue until May 2026. This phase will include:

• Registration of Category 2 GO and GOP candidates

• Recommended Action: Generator Owners and Generator Operators should expect to begin the registration process for existing, non-registered Category 2 assets starting in May 2025. GridSME highly recommends, whenever possible, starting this process as soon as practicable.

2) What is Category 2 and how do I know if my project is required to register?

NERC has identified a new definition, Category 2, that outlines the thresholds and project characteristics that will trigger GO-IBR registration. If your project meets the criteria in one of the Categories identified below, it will need to go through the process of registration. The Category 1 and Category 2 terms are defined as:

Category 1:

• Category 1 identifies IBRs currently registered today, and meeting NERC GO thresholds of greater than or equal to 75 MVA nameplate rating and interconnected at a voltage greater than or equal to 100kV. 

Category 2:

• Category 2 is a new term that identifies IBRs not registered today that are greater than or equal to 20 MVA nameplate rating and interconnected at a voltage greater than or equal to 60 kV.

3) Standards Update and Changes Impacting GO-IBR: Click Here

While the specific Standards required for GO-IBR projects have not been officially stated, NERC’s Standard Drafting Team (SDT) has identified currently in progress updates and changes to Standards that will be effective for both Category 1 and Category 2 sites. The Standards summarized below have been identified as IBR/DER-related projects to address FERC Order No. 901:

• PRC-028-1: In April 2023, NERC’s (SDT) submitted a revised SAR to create a new Standard (PRC-028-1) for monitoring requirements for BES connected IBRs and Non-BES connected IBRs that either have or will contribute to an aggregate nameplate capacity of greater than or equal to 20 MVA and interconnected at a voltage greater than or equal to 60kV.
• Status of Standard: The second 25- day comment period and formal ballot was posted from March 18 through April 11, 2024 with a waiver.
• Tentative Deadline for Compliance: Entities shall comply with Requirements R1 through R7 at 50% of their generating plants/Facilities within three (3) calendar years of the effective date of PRC-028-1 and 100% of their generating plants/Facilities by January 1, 2030.

• PRC-024-3: The Standards Committee authorized drafting of revisions to PRC-024-3 or replacing the Standard with a performance-based ride-through Standard. FERC Order 901 requires that IBR-related performance requirements for ride-through are completed and filed with FERC by November 4, 2024. The functional entity responsible for assuring acceptable ride-through performance of IBR is the Generator Owner (GO) and Transmission Owner (TO). Applicable Facilities include any IBR that meets NERC registration criteria and are those Facilities consistent with FERC Order No. 901.
• Status of Standard: Pending results of comment period and ballot
• Tentative Timeline:
• Effective date for PRC-024-4 is six (6) months after approval by applicable governmental authority
• Effective date for retirement of PRC-024-3 is immediately prior to effective date of version 4
• Effective date for PRC-029-1 is six (6) months after approval by applicable governmental authority while requirement R6 is effective another six (6) months after (12 months total following approval)

• PRC-030-1: Due to multiple NERC disturbance reports, PRC-030-1 Unexpected Inverter-Based Resource Event Mitigation was developed and the formal comment period and initial ballots for draft one concluded on Thursday, April 18, 2024. The SAR Drafting Team believes this new Standard should be developed and implemented to ensure any unexpected ceasing of current injection (partial or full) is analyzed by the applicable GO and mitigated to the extent possible.
• Status of Standard: Pending results of 25-day initial ballot and comment period, which closed on April 18, 2024.
• Tentative Deadline for Compliance: PRC-030-1 shall become effective on the first day of the first calendar quarter that is six (6) months after the effective date of the applicable governmental authority’s or NERC Board of Trustees order approving the Standard, or as otherwise provided for by the applicable governmental authority or NERC Board of Trustees.

4) What other Standards should we expect?

GridSME’s team has participated in various committee meetings, and we have been tracking the progress of the new IBR registration initiative since its inception. Our SMEs have provided a speculative summary of the additional Standards that may be applicable to the Category 2 sites, based off of FERC Order 901’s four key areas of risk. Those Standards we anticipate for Category 2 sites include:

• CIP-002 – Cyber Security – BES System Categorization
• CIP-003 – Cyber Security – Security Management Controls
• EOP-004 – Event Reporting
• EOP-012 – Extreme Cold Weather Preparedness and Operations
• FAC-003 – Transmission Vegetation Management
• FAC-008 – Facility Ratings
• IRO-010 – Reliability Coordinator Data Specification and Collection
• MOD-025 – Verification and Data Reporting of Generator Real and Reactive Power Capability and Synchronous Condenser Reactive Power Capability
• MOD-026 – Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions
• MOD-027 – Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions
• MOD-032 – Data for Power System Modeling and Analysis
• TOP-003 – Operational Reliability Data
• VAR-002 – Generator Operation for Maintaining Network Voltage Schedules

5) NERC’s 2024 Q1 Update: Click Here

NERC released a 2024 First Quarter Update, which can be found at the link above. In this update, NERC highlighted key activities that took place. Some of those include:

·       NERC Board of Trustees approval of the proposed revisions to the NERC Rules of Procedure in February 2024.

• IBR Registration Initiative Quick Reference Guide
• Frequently Asked Questions Guide

In the NERC ROP, will the unregistered IBR owners and operators be classified using the current GO and GOP functional entities as defined in the ROP’s Registry Criteria, respectively?

The Category 2 GOs and GOPs will be a new category of GOs and GOPs in the ROP as reflected in the proposed ROP revisions.

What was the technical justification behind NERC’s proposed expansion of the Registry Criteria?

NERC’s analysis of energy data from 2016 to 2021 found that around 14% of certain operational power resources weren’t covered by the NERC Reliability Standards, while only 3% of synchronous capacity wasn’t registered. Check NERC’s filings for more info, including the Quick Reference Guide on Inverter-Based Resource Activities for technical assessments related to integrating these resources and their impact on power system reliability.

What is the Purpose of the IBR Order?

The IBR Order aims to ensure the reliability of the bulk power system by identifying and registering owners and operators of IBRs that have a significant impact on the operation and reliability of the power grid.



What are the Proposed Changes to NERC’s Rules of Procedure (ROP)?

NERC has proposed revisions to its ROP, specifically affecting Appendices 2, 5A, and 5B. These revisions include the addition of Category 2 Generator Owners (GOs) and Generator Operators (GOPs) and other adjustments to accommodate the registration of currently unregistered IBRs.

Why Expand the Registry Criteria?

NERC’s analysis found that a significant portion of operational IBRs were not subject to the NERC Reliability Standards, raising concerns about the reliability of the bulk power system. Hence, the proposed expansion aims to address these reliability risks.

Classification of Unregistered IBR Owners and Operators:

Owners and operators of currently unregistered IBRs with aggregate nameplate capacities of 20 MVA or more, delivering such capacity at 60 kV or higher, will fall under Category 2 GOs and GOPs in the revised ROP.