NERC Standards Committee Tackles Final Order 901 Tranche

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FERC Order 901 directs NERC to develop reliability standards addressing inverter-based resources such as wind and solar generators.
FERC Order 901 directs NERC to develop reliability standards addressing inverter-based resources such as wind and solar generators. | Kevin Dooley, CC-BY-SA 2.0, via Wikimedia Commons
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NERC's Standards Committee agreed to post two inverter-based resource-related standard authorization requests for industry comment at its monthly meeting.

With NERC entering the final phase of a FERC-directed standards project to address reliability risks of inverter-based resources, the chair of NERC’s Standards Committee said the ERO aims “to use [its] resources efficiently and wisely” to meet the commission’s deadline. 

Meeting via teleconference Aug. 20, SC members voted to move forward with two standards authorization requests (SAR) for the fourth and final milestone of Order 901, in which FERC directed NERC to develop requirements pertaining to the reliable connection and operation of IBRs. (See FERC Orders Reliability Rules for Inverter-Based Resources.)  

Milestone 4 of the order mandates that NERC submit standards by Nov. 4, 2026, “addressing planning and operational studies for registered IBRs, unregistered IBRs and IBR-DERs [distributed energy resources] in the aggregate” (RM22-12). Previous milestones concerned IBR performance requirements, including voltage and frequency ride-through, disturbance monitoring data sharing and post-event performance validation.  

The SARs approved in the SC meeting tackle planning and operational studies separately and already have been reviewed by NERC’s Reliability and Security Technical Committee. (See NERC RSTC Tackles Priority Projects in Quarterly Meeting.) With the committee’s approval, both SARs will be posted for a 30-day informal comment period, and NERC will solicit nominations for drafting team members for at least 15 days; the operational studies team will be designated Project 2025-03, while those working on planning studies will be Project 2025-04. 

NERC Manager of Standards Development Sandhya Madan told listeners that considering the deadline, NERC has classified both projects as “high priority,” which the ERO applies to projects that address “significant” risks as identified by the following criteria: 

    • subject of a NERC or FERC directive with a set due date; 
    • identified as a priority in NERC’s work plan; or 
    • recommended to address a specific risk by compliance feedback, stakeholder feedback or a study. 

Also considered high priority was NERC’s project to revise CIP-015-1 (Cybersecurity — internal network security monitoring), approved by FERC during its June open meeting. (See FERC Approves NERC’s Proposed INSM Standard.) In its order approving the standard, the commission directed the ERO to require that utilities extend the implementation of INSM to electronic access control or monitoring systems and physical access control systems outside their electronic security perimeter, the electronic border around their internal networks. 

To meet FERC’s deadline of submitting the revisions by Sept. 1, 2026, NERC solicited 19 nominations from industry and recommended appointing 15 nominees to the project team, including a chair, two co-vice chairs and 12 members. NERC Manager of Standards Development Alison Oswald said the ERO desired two vice chairs instead of the usual one “to make sure that there’s always someone from the leadership team that can be able to attend the [project’s] numerous expected calls and in-person meetings.” 

Oswald also confirmed that nine of the 15 recommended members, including at least one member of the leadership team, will return from the team that drafted the original standard. The proposal passed without objection. 

A proposal to appoint five candidates to supplement the team for Project 2017-01 (Modifications to BAL-003 — Phase 2), which has lost four members who are retired or no longer able to serve, sparked some discussion after Robert Blohm of Keen Resources suggested adding a sixth member to achieve regional balance. The aims of the low-priority project include addressing “the real-time aspects of frequency response necessary to remain reliability [and developing] measurements to incorporate real-time resource and load characteristics.” 

Blohm said his proposed candidate, who like other nominees was not identified by name during the meeting, had “the most direct subject matter drafting team experience” of all the nominees. In addition, he pointed out that the five candidates recommended by NERC represented five of the ERO’s six regions and that adding this person would ensure all regions were represented.  

Other members were reluctant to take up Blohm’s cause, with several indicating they trusted NERC’s vetting. Oswald said NERC felt the five recommended candidates had “the correct mix of regional representation and utilities that would be subject to the standard,” but suggested the remaining candidates “would be great additions as active observers on the project.” Blohm’s motion to add the candidate failed with 13 votes against and five in favor; a subsequent motion to approve NERC’s slate passed unanimously. 

Finally, members agreed to authorize a 30-calendar day solicitation of nominations to supplement the team for Project 2022-05 (Modifications to CIP-008 reporting threshold), which has also seen four members depart since its inception in 2023.  

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