By Terry Brinker
As a former manager of registration for the North American Electric Reliability Corporation (NERC) and president and CEO of Reliable Energy Advisors, I have written articles about the risks and challenges of NERC regulations.
In my article “Your Audit Report May Be Worthless,” I warned of falling into the trap of thinking your organization has a strong compliance program because you passed an audit.
Today, I am sounding the alarm about potentially hundreds of facilities being swept up into the NERC regulatory world where fines and penalties can be as high as $1 million a day per violation.
Recently, NERC unveiled updated rules for inverter-based resources (IBRs), which are reshaping the landscape for utilities and energy producers. These new standards aim to enhance grid reliability and security in light of the increasing integration of renewable energy sources, such as solar and wind, into the electric grid.
For utilities not currently registered with NERC, these changes bring unique challenges and obligations. For entities that are registered and have additional facilities that will meet the new thresholds, more documentation will be needed.
To ensure a smooth transition, nonregistered entities must prepare proactively for NERC registration and adherence to NERC standards. This is no small feat, particularly for newcomers to NERC. In addition, unlike in the past where registration was a voluntary process, NERC has coordinated with reliability coordinators and transmission operators to identify entities that meet this new threshold.
Escaping NERC registration will be unlikely.
Understanding the New NERC Rules for Inverter-based Resources
NERC’s updated rules focus on addressing the operational and cybersecurity challenges posed by IBRs. The new requirements emphasize:
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- Performance Validation: Ensuring that IBRs can withstand and recover from disturbances without jeopardizing grid stability.
- Data Sharing: Mandating detailed operational data submissions for elective grid planning and operations.
- Cybersecurity: Strengthening the security framework to safeguard inverter-based systems against cyber threats.
These requirements reflect NERC’s commitment to integrating renewable energy resources while maintaining the reliability and resilience of the bulk electric system (BES).
Steps for Utilities Preparing for NERC Registration
For utilities not currently registered with NERC, the prospect of registration and compliance can be daunting. However, following a structured approach can streamline this transition:
Assess Applicability: Not all utilities are subject to NERC’s rules. Entities must determine whether their operations meet NERC’s criteria for registration. This includes evaluating the size, capacity and operational impact of their resources on the BES. If you have a facility (or facilities) with a 20-MVA nameplate rating and connected at 60 kV or higher, the countdown is on for you to register.
Conduct a Gap Analysis: Perform a thorough gap analysis to identify areas where your operations diverge from NERC standards. This involves:
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- Reviewing the new IBR requirements.
- Identifying which NERC standards apply to your organization.
- Assessing current operational, cybersecurity and data management practices.
- Identifying deficiencies and areas needing improvement.
Develop a Compliance Program: A robust compliance program is critical for meeting NERC standards. Key components include:
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- Policies and Procedures: Develop clear and comprehensive documentation of processes.
- Training: Educate staff on NERC compliance obligations and the new IBR rules.
- Monitoring: Implement tools for continuous monitoring and reporting of compliance metrics.
Engage with Industry Experts: Collaborate with NERC-registered utilities or consulting firms specializing in regulatory compliance. Their expertise can provide valuable insights into best practices and help navigate complex requirements.
Prepare for Audits and Registration: Mock audits and readiness assessments are essential for ensuring compliance. These activities simulate NERC’s evaluation processes and allow utilities to address gaps before official audits.
Key Considerations for NERC Compliance
Documentation: Maintain meticulous records of all compliance-related activities, including testing, training and incident responses.
Technology Investments: Upgrade existing systems to meet performance and cybersecurity standards for IBRs.
Stakeholder Engagement: Work closely with regulatory bodies, industry peers and technology providers to ensure alignment with NERC expectations.
Conclusion
The new NERC rules for IBRs signify a pivotal moment for utilities, especially those not yet registered with NERC. By proactively assessing their readiness, addressing operational gaps and implementing robust compliance programs, these entities can position themselves to meet NERC’s standards effectively.
Early preparation not only ensures compliance but also fosters a more resilient and secure grid as renewable energy continues to grow in prominence. As the energy industry evolves, adhering to NERC’s regulations is not merely a regulatory obligation — it is a critical step toward supporting a sustainable and reliable energy future.
Did I mention not adhering to NERC’s regulations can result in fines and penalties up to $1 million a day per violation?
Terry Brinker is a 30-year industry professional with experience leading, facilitating and implementing improvements in power plant operations, control room operations, compliance and regulatory matters.