NERC is seeking comment from industry stakeholders on proposed changes to the organization’s Rules of Procedure (ROP) intended to meet FERC’s order from last year to identify and register the owners of grid-connected inverter-based resources (IBRs).
The ERO posted the proposal for a 45-day comment period Wednesday, citing the commission’s November order directing NERC to describe its plans for registering IBRs (RD22-4). (See FERC Addresses IBRs in Multiple Orders.) NERC submitted its registration strategy in February, and FERC approved the work plan in May. (See FERC Approves NERC’s IBR Work Plan.)
FERC’s order was motivated by concerns over the ongoing transition from conventional generation resources to IBRs like wind and solar facilities. Currently, the ERO’s rules defining which resources must register with NERC, follow its reliability standards and respond to its alerts do not apply to many smaller IBRs. Updating the ROP is the first step in NERC’s work plan. The next stages are identifying candidates for registration, to be done by May 2025, and carrying out the registration process, to be finished by May 2026.
The changes before industry will apply to Appendices 2 (Definitions), 5A (Organization registration and certification) and 5B (Compliance registry criteria) of the ROP.
In Appendix 2, NERC proposes to add two new definitions — generator owner-IBR (GO-IBR) and generator operator-IBR (GOP-IBR) — to the registry criteria, while also updating the definition of “reserve sharing group” (RSG) to be consistent with that proposed by Project 2022-01 (Reporting ACE definition and associated terms).
The addition of GOP-IBR represents a change from the work plan NERC submitted in March, which included only GO-IBR. NERC staff said at the time that it felt GO-IBR could be used in reference to both owners and operators of IBRs, but at FERC’s prodding, it pledged to consider using additional terms.
Proposed changes to Appendix 5A include adding the GO-IBR, GOP-IBR and distribution provider-underfrequency load shedding (DP-UFLS or UFLS-DP) functions to the registration functions list. The DP-UFLS term indicates entities that own, control or operate UFLS-protection systems needed to implement grid protection programs but do not meet any of the other criteria for registering as distribution providers. NERC also proposes to clarify the Compliance Committee’s process for reviewing registration appeals.
The revisions to Appendix 5B would specify that entities registered as GO-IBRs or GOP-IBRs must own and maintain, or operate, inverter-based generation resources with an aggregate nameplate capacity of at least 20 MVA, which deliver their capacity to a common point of connection at a voltage at least 60 kV. Additional revisions will further clarify which entities should be considered candidates for registration, remove dated information and add the RSG function to ensure consistency with Appendix 2 and Project 2022-01.
The ERO will accept comments on the proposed changes through Oct. 30. After the comment period is over, NERC plans to submit the changes for approval at the Board of Trustees’ next meeting in December and then to FERC for final approval.
