To no one’s surprise, the big tent of reliability regulations is expanding to include more invertor based resources, or IBR. On November 17, 2022, the Federal Energy Regulatory Commission (FERC), issued an order directing the North American Electric Reliability Corporation (NERC) to file a Work Plan within 90 days to address IBR registration.

This proposed registration includes possible application of a subset list of Reliability Standards which would apply to IBR Generator Owners (GO).

Who would the new standards apply to?

The new proposed registration criteria include the following:

• Owners of IBRs which have aggregate nameplate capacity of less than or equal to 75 MVA and greater than or equal to 20 MVA interconnected at a voltage greater than or equal to 100 kV
• Owners of IBRs which have aggregate nameplate capacity of greater than or equal to 20 MVA interconnected at a voltage less than 100 kV

Which Standards are impacted?

The applicable group of Reliability Standards would include those focused on the key parameters for BPS reliability – facility interconnection analysis, data for modeling and verification, and protection coordination and resource performance. The standards include, but are not limited to:

• FAC-002 (facility interconnection)
• IRO-010 and TOP-003 (data)
• MOD-025, MOD-026, MOD-027, and MOD-032 (modeling)
• PRC-019 and PRC-024 (protection and performance)
  

Keep in mind this is a starting point of the scope applicability. However, it is impossible to believe other protections devoted to the areas of cyber security (CIP) and emergency operations (EOP) will not be part of the final list of requirements.

What does it mean to me?

Looking ahead, GOs should review the information to determine if the proposed registration and scope of applicable standards Help, Hurt, or have No Effect on operations and costs.

Help – Inclusion in the group of BES elements (Bulk Electric System) may substantiate the value of the project through the implementation of the additional protections. Contributing to system reliability is more valuable than being indifferent to it. Plus, investors may view projects that incorporate reliability requirements into their operations as a superior investment compared to those that continue to operate outside BES designation.

Hurt – Risk of exposure to regulations may be deemed excessive because of the need to set up a compliance program and the potential sanctions from non-compliance. That risk is substantially mitigated by readily available Generator Owner and Operator compliance tools that have been successfully deployed for years. Once incorporated into a well ordered compliance program, the production of compliance evidence is integrated into both the commissioning of new facilities and the ongoing operation of established generators. No extraordinary efforts are required.

No effect – The proposed scope of standards consists primarily of data exchange responsibilities. Operational details of the increasing fleet of IBRs is crucial to coordinated system operations. The facilities themselves tend to be highly stable and dependable within their design characteristics. A wider dissemination of the operational attributes and limitations of the facilities will enable better planning and coordination of the entire interconnection electric system. Deriving the data and maintaining evidence of its existence and periodicity of communication is not burdensome.

As of right now, the key point is changes are underway that will significantly affect the operation and responsibilities of generation resources. Fortunately, developers and operators need not stand by and await the outcome of the registration and compliance details. The FERC and NERC processes are open and inclusive, and the process will benefit from the input and insights of the IBR resources.

When ready, NERC will post Rules of Procedure revisions for public comment period on NERC website for 45 days. Affected entities can comment in one of two ways:

• Monitor the NERC Standards, Compliance, and Enforcement Bulletin. The bulletin will advise when the comment period is open.
• Contact us – we’ll let you know when the information is posted for comments
  

Although the timeline for implementation of these measures is planned over the next three years, now is the time to understand the details of what is being proposed and provide input into the process. The results of these changes will affect IBRs for decades to come.