NERC Proposes Changes to Registration Criteria for Inverter Based Resources (IBRs)

NERC has submitted for FERC approval new compliance criteria for the registration of IBRs as part of continuing efforts to address reliability risks. It is critical for renewable energy developers, generation owners and transmission owners to understand the potential implications for interconnection studies and interconnection queues.

As explained in its filing, NERC is proposing to update the Generator Owner and Generator Operator (“GO” and “GOP”) Registry Criteria to include a new category (“Category 2 GOs” and “Category 2 GOPs”) of entities that own or operate non-BES inverter based generating resources that:

• Either have or contribute to an aggregate nameplate capacity of greater than or equal to 20 MVA, or
• Connected through a system designed primarily for delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV.

Drivers for the Change

For several years, the ERO Enterprise has been publicly identifying the impact on reliability associated with the transformation of the generating resource mix, resulting in the increased integration of IBRs.

In the opinion of FERC and NERC, these assessments have adequately demonstrated a change in long-held assumptions regarding the reliable operation of the power system. If not prudently managed, the accelerated integration of IBRs will create new technical interoperability challenges that pose a risk to reliability. As a precautionary measure, NERC issued its IBR Strategy and explained:

“The speed of this change continues to challenge grid
planners, operators, protection engineers, and many other
facets of the electricity sector. Implemented correctly,
inverter technology can provide significant benefits for the BPS;
however, the new technology can introduce significant
risks if not integrated properly. Based on recent analysis,
these are high impact and high likelihood events that require
substantive action by the ERO as called out by the NERC
Framework to Address Known and Emerging Reliability and
Security Risks (NERC Risk Framework).”

The NERC Inverter-Based Resource Strategy is a four pillared plan to address these technical issues and reliability needs. One pillar is to pursue enhancements to the regulatory model under section 215 of the Federal Power Act which includes the NERC registration criteria.

NERC’s approach is reflected in the Quick Reference Guide, IBR Strategy, and indicated that 16% of materially impactful IBRs are currently not subject to registration and compliance with NERC Reliability Standards as they are non-BES IBRs.

Given the proposed registration criteria and the applicability of compliance requirements related to IBRs in the interconnection queue, it is critical for TRC clients to plan ahead and make adaptations to their interconnection study process.

FERC Approval may be expedited

NERC is seeking FERC’s expedited approval for the compliance registry criteria, given the many challenges it helps mitigate. An approval order from FERC may be issued relatively quickly.

Timeline

Next Steps: TRC Can Help

TRC has expertise in power generation, protection and controls, and power delivery engineering and can complete an independent review of your company’s power reliability performance of IBRs.

We can help your company meet the coming requirements in this area of focus and expediting your reliability risk mitigation and NERC compliance efforts.

Resources

NERC March 19, 2024 Filing to FERC to Modify its Compliance Registry Criteria

NERC’s IBR Registry Criteria Quick Reference Guide

NERC Inverter Based Resource Strategy

NERC Rules of Procedure Page

NERC Compliance Consultants

Power System Studies

Your Trusted Regulatory Advisor

TRC closely follows the national, provincial, and state regulatory trends in all regions of North America. Our approach to power system security, engineering, planning, design, construction and commissioning testing, balances solutions that incorporate industry reliability risk trends, mandatory reliability standard requirements, regulatory guidance, compliance obligations, best practices, operational goals, and budgets. With expertise in power system planning, engineering, and operations. TRC supports public utilities and private energy providers in their efforts to stay ahead of the regulatory curve and to meet or exceed regulatory requirements as they evolve.

This regulatory update is provided as a service to TRC’s utility clients, helping to keep you informed of forward-looking issues that will impact your company’s electric system reliability risks along with related topics regarding regulatory developments, to help you achieve your company’s business goals.