In separate orders issued Sept. 25, FERC denied a request for clarification of its order approving NERC’s new inverter-based resources ride-through standards, along with updating how the commission processes certain filings from the ERO.
FERC approved NERC’s IBR ride-through standards, PRC-024-4 (Frequency and voltage protection settings for synchronous generators, Type 1 and Type 2 wind resources, and synchronous condensers) and PRC-029-1 (Frequency and voltage ride-through requirements for IBRs) in Order 909, issued July 24.
PRC-029-1 contained an exemption period that would give owners of legacy IBRs — resources already in operation when the standard goes into effect — 12 months after the effective date of the standard to request an exemption to the ride-through requirements.
The order dealt with IBRs equipped with choppers, which are used in offshore wind projects to protect converters by dissipating excess power during grid faults. It directed NERC to determine whether those resources have challenges meeting the ride-through standards and account for the difficulty — and to estimate the “lead time between adopting IBR specifications and placing the IBR in service.” NERC must submit its determination, along with any other exemptions it deems appropriate, within 12 months of Aug. 28, 2025, the effective date of the order.
However, the American Clean Power Association and the Solar Energy Industries Association (acting jointly as “Energy Trades”) then filed a request for clarification of the order Aug. 25 (RM25-3). The organizations expressed concern that, with PRC-029-1 to take effect Oct. 1, 2026, the industry would not have enough time to “make legally effective any proposed modifications submitted by NERC” if the ERO waited until Aug. 28 to make its filing, and claimed this “regulatory uncertainty” could create reliability risks in some regions.
The Energy Trades asked FERC to clarify that NERC did not have to wait until Aug. 28 to file, and even encouraged NERC to file by May 28, 2026, saying “this would give the commission sufficient time to act on the filing.” But FERC declined to issue this clarification, said it considered the 12 months already given “a reasonable time frame for NERC to … make its decision” and expressed confidence the ERO would not delay its filing unnecessarily.
FERC also pointed out that NERC has several options to address the Energy Trades’ concerns, such as updating its implementation plan for the modified standard or exercising its enforcement discretion to defer enforcement while registered entities implement the requirements.
OER to Hear More NERC Cases
The commission’s orders also included a final rule reassigning the handling of certain NERC filings from the commission’s Office of Energy Market Regulation (OEMR) to the Office of Electric Reliability (OER) (RM25-13).
Under current FERC regulations, the director of OER has the authority to approve uncontested applications from NERC, except applications pursuant to sections 39.8 and 39.10 of the regulations, which are handled by OEMR. Those sections respectively involve: proposals to delegate the ERO’s enforcement power to a regional entity; and proposed organizational rules or rule changes, including any RE rule or rule change.
The change, which will bring all uncontested NERC applications under the purview of OER, was decided because of the office’s “frequent interactions with the ERO and OER’s applicable expertise,” commissioners said in the order. It will take effect immediately upon the order’s publication in the Federal Register.
