A set of proposed changes to NERC’s Rules of Procedure (ROP) that would create a process for registering owners and operators of inverter-based resources (IBRs) will go before the ERO’s Board of Trustees for a vote in February, the organization announced this week.
NERC developed the proposed ROP changes last year as stage 1 of its three-stage registration process, which FERC approved in May (RD22-4). (See FERC Approves NERC’s IBR Work Plan.) The process specified that NERC would submit the first stage to the commission within a year after approval; the second stage, identifying candidates for registration, is to be completed within two years, with registration to be finished within three years.
The rule changes will affect Appendices 2, 5A and 5B of the ROP; respectively, these concern definitions of terms used in the ROP, NERC’s Organization Registration and Certification Manual, and the compliance registry criteria.
In Appendix 2, NERC intends to update the definitions of generator owner (GO) and operator (GOP) to include “entities that own and maintain or operate [grid]-connected … IBR.” The proposed changes would also update the definition of “reserve sharing group” (RSG) to be consistent with what was proposed in Project 2022-01 (Reporting ACE definition and associated terms), which passed its final ballot in December.
The RSG changes are part of NERC’s planned changes to Appendix 5B as well. In addition, the ERO proposed to add a new category to the GO and GOP registry criteria for entities that own and maintain or operate IBRs with aggregate nameplate capacity of at least 20 MVA, working through a common point of connection with a voltage of at least 60 kV. Further changes will clarify which entities are candidates for registration and have access to NERC’s review panel process.
Finally, Appendix 5A will be updated to “reflect NERC’s scope of authority to register entities that own, operate or use [grid] assets consistent with the revisions in Appendix 5B,” and to clarify the type of review to be applied to registration appeals.
NERC posted the proposed changes for industry comment from Sept. 13 to Oct. 30. The final ROP changes before the board next month will reflect the feedback the ERO received through this process.
In response to a comment from Advanced Energy United expressing concern about a supposed lack of specificity regarding which facilities are to be registered, NERC said it would update the definition in Appendix 2 with more detail about whether IBRs outside the Bulk Electric System (BES) — and therefore not subject to NERC’s reliability standards — would be required to register.
The Edison Electric Institute and Evergy also expressed concern about the “unintended consequences” that could arise from the use in the proposal of the term “bulk power system” (BPS), which refers to the entire electric grid, including facilities not subject to the ERO’s standards. The respondents explained that while BES is “well understood [and] used in the context of the applicability of reliability standards,” BPS is less well defined and consequently could “lead to ambiguity and confusion.”
NERC replied that the ERO “is not modifying its approach to ensure that reliability standards … support an adequate level of reliability,” and that the ROP updates will not impact its standards development or compliance enforcement efforts.
In addition, NERC incorporated clarifications to Appendix 5B in response to a concern from AEU that the proposal lacked a means to appeal registration decisions for non-BES facilities. The final proposal will reflect that the “registration review panel process is available to owners, operators and users of the BPS, not only BES.”
