The North American Electric Reliability Corporation (NERC) has introduced a new registration category— Category Two (Cat 2)— for generator owners. If your assets are connected at 60 kV or higher and rated at 20 MVA or more, this designation likely applies to you.
While some compliance requirements are already outlined, much of the regulatory framework is still evolving. That means the path forward won’t be marked by hard deadlines alone— it will be shaped by ongoing guidance, interpretation, and industry input.
A Focused List, for Now
As it stands, Cat 2 facilities are expected to comply with a defined set of nine standards, including MOD-032, PRC-028, and VAR-002. But this list is only a starting point.
Several standards— including CIP-002 and CIP-003 (cybersecurity), FAC-008 (equipment ratings), and PRC-005 (protection system maintenance)— are likely additions based on industry analysis and past application. Furthermore, a broader convergence between Cat 1 and Cat 2 obligations over time is expected, especially as inverter-based resources (IBRs) become more integral to grid operations.
“It’s not just these nine standards,” says Kellie Macpherson, Executive Vice President of Compliance and Security here at Radian. “We’re moving toward a model where Category One and Category Two facilities share a more unified set of expectations.”
What This Means for You
This moment offers a valuable opportunity: not just to prepare for what’s been published, but to develop a flexible, forward-looking compliance strategy that can adapt as standards evolve.
“If I was you and I was looking at this list, what would I be thinking about, from what I know from industry?” says Kellie.
Some steps worth considering:
- Review your facility’s system documentation and identify gaps in testing or operational readiness.
- Engage with advisors who are following the drafting process closely— and can help interpret how changes may apply to your sites.
- Stay informed not just about the “what” of compliance, but the “why” behind it. Many of the anticipated standards are core to grid reliability and cybersecurity, regardless of asset size.
Our team at Radian is actively involved in industry working groups and drafting teams as this project develops. Make sure you’re following us on LinkedIn, and check here for more updates and resources to help you understand where things stand—and where they’re headed.
🎥 Get a deeper dive in our new video with Kellie Macpherson:
