3 Things to Know About NERC’s “Work Plan”

The Federal Energy Regulatory Commission (FERC) issued an order on May 18, 2023, titled “Order Approving Registration Work Plan.” This new order directs the North American Electric Reliability Corporation (NERC) to move forward with its plan for identifying and registering owners and operators of inverter-based resources (IBRs) that are connected to the bulk power system.  

The change specifically targets IBRs that have not previously been required to register with NERC under its definition of bulk electric system (BES). Here are three crucial things you need to know about this most recent FERC order. 

1. New NERC Registration Requirements

The Federal Power Act (FPA) defines the bulk power system as “facilities and control systems necessary for operating an interconnected electrical energy transmission network (or any portion thereof), and electric energy from generating facilities needed to maintain transmission reliability. The term does not include facilities used in the local distribution of electric energy.”

Owners, operators, and users of the bulk power system must register with NERC if they meet the agency’s criteria through either the BES definition or a materiality test of an entity’s elements and facilities. According to NERC, if an entity is deemed “material to the reliability of the bulk power system,” it requires registration. 

NERC uses a bright-line criteria, meaning all elements connected at 100 kV or higher. After the application of these criteria, additional elements may be identified. NERC reserves the right to make adjustments to its standards, which it has done with these new registration requirements. 

NERC has proposed revisions to its Rules of Procedure and Registry Criteria to include a new entity called “GO-IBRs,” which is short for Generator Owner IBRs. GO-IBRs would include IBRs that…

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

These new requirements do not currently apply to IBRs that are distributed energy resources (IBR-DER) or those that connect to the local distribution system. 

2. Identifying Who Needs to Register

FERC’s procedural move to enhance the reliability of the bulk power system requires owners of certain inverter-based resources (IBRs) to register and meet other standards. 

In its work plan, NERC described an examination of Regional Entities between 2017-2021.

The study revealed that the total nameplate capacity of IBRs on the bulk power system rose by 73 GW over that period, and while IBRs accounted for more than 15% of the bulk power system’s nameplate capacity in 2021, just 84% of the IBRs were registered with NERC. This leaves a 16% gap in registration, and NERC estimates that many of the unregistered IBRs consist of resources that are 20 MW or greater. 

This is why NERC has proposed the new GO-IBR criteria with a 20 MVA threshold. How NERC plans to identify who needs to register has yet to be determined, but those who must register will also be subject to a subset of the NERC standards.

3. Timeline for Registration

NERC has proposed a three-phase approach to identifying and registering certain unregistered IBRs to be completed within 36 months of the plan’s approval. These deadlines are subject to change as NERC and FERC have not finalized the details.  

According to NERC’s filing and work plan, the agency will…

• …revise its Rules of Procedure to include GO-IBRs as a new registered entity within 12 months of Commission approval.
• …identify candidates for GO-IBR registration within 24 months of Commission approval.
• …register GO-IBRs within 36 months of Commission approval of the plan. 

Realistically, everyone subject to the new rules should expect to be fully compliant by March 2025. What’s important to understand is that some GO-IBRs will need to make some significant changes to achieve compliance.

Determine Whether or Not You Are Subject to NERC Compliance

The changes proposed by the most recent FERC order can be confusing, and the agency hasn’t issued a final order detailing compliance deadlines, so it’s important to begin preparation immediately. If your IBR is now subject to registration and includes legacy systems, it may require substantial upgrades to comply with NERC cybersecurity standards. If you’re concerned about who is on the list or which of your projects would have to register, Radian Generation can help. We are an experienced and trusted provider of NERC implementation and long-term compliance management services. Contact us if you would like to learn more about how we can help your business!

*Since publication of this Blog post on July 11, 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.