Upcoming NERC Threshold Changes – Part One

What you Need to Know

In May of this year (2023), the Federal Energy Regulatory Commission (FERC) issued new guidelines for Inverter Based Resources which are meant to protect and enhance the reliability of the bulk power system. In a work plan submitted by the North American Electric Reliability Corporation (NERC), the agency aims to change the threshold for registration and regulatory compliance.

Basics of the NERC Standards

NERC was formed in the 1960s and has since been designated as the Electric Reliability Organization (ERO) for the United States and parts of Canada. NERC has created a variety of standards meant to provide assurance to the public, government, and industry of a reliable bulk power system. The agency enforces standards that cover things like facility planning, business functions, voltage and balancing, emergency preparedness, and interconnectivity. 

Upcoming NERC Threshold Changes

On February 15, 2023, NERC submitted its compliance filing with a plan to identify and register owners of inverter-based resources (IBR) that are connected to the bulk power system but have not been required to register with NERC under the definition of Generator Owner.

The NERC plan defines IBRs to include solar photovoltaic and battery resources that change direct current power produced into alternating power so it can be transmitted on the bulk power system. 

In 2022, FERC required NERC to create a plan to identify IBRs that are not currently registered with NERC but have a material impact on the reliable operation of the bulk power system. The expected NERC threshold changes will create a new group of Generator Owner IBRs (“GO-IBRs”), comprised of IBRs that…

  • …have aggregate nameplate capacity of 20 to 75 MVA interconnected at voltage levels of at least 60 kV*

NERC intends to register IBRs subject to the new requirements through changes to its registration program. 

Why the Changes Matter

These changes matter because if your IBR is now subject to NERC registration, that means it is also required to adhere to certain reliability standards. In addition to registering with NERC, you will need to ensure your IBR is in compliance with these rules

Who the Changes Will Affect

The new changes will affect owners of inverter-based resources (IBRs). According to NERC, these new criteria will impact a large percentage of the IBRs connected to the bulk power system that are not already registered. Some older facilities that weren’t affected before will potentially be impacted by these changes. 

When the Changes Will Take Effect

The upcoming NERC threshold changes are expected to take effect over the next two years. The agency’s order outlines some specific dates for registration and compliance. We expect that everyone will be required to be fully compliant by March 2025. To be clear, this isn’t the date that teams should begin taking action on compliance. The time to start working on the required changes is now

Reach Out to Radian Generation for NERC Compliance Expertise

NERC compliance is a serious issue. Failing to comply can result in financial penalties. Radian Generation can help you ensure that you remain compliant with NERC standards.

If you’re unsure of whether or not you will be affected by the upcoming changes, we can help. Our NERC experts assist clients with long-term compliance management, including documentation, asset management, periodic submittals, and audit support. Contact us if you would like to learn more about our services!

*Since publication of this Blog post on June 30, 2023, NERC revised the new GO-IBR interconnection voltage criteria from a minimum of 100kV to 60kV. Radian Generation will work to keep this Blog post updated as changes to the regulations unfold.