NERC Compliance Timing for New BES Generating Facilities

NERC Compliance Timing

An important question that we often hear when a client is constructing a new BES Generating Facility is, “When is the facility required to be fully compliant with all NERC Standards? Is it the registration date, the date of first synchronization to the grid, the Commercial Operation Date (COD), or some other date?”

In the past, some Regional Entities required generating plants to register and meet compliance on the date the facility was first synchronized to the grid. That at times presented challenges, as many commissioning and testing activities could not be completed until after first sync. Recently, NERC and the Regions have agreed the compliance and registration date for new generation should be the COD. Note there are some exceptions, such as the MOD-025, MOD-026 and MOD-027 standards, where the compliance date is 12 months after COD.

Moving away from first sync is a big step in the right direction. It’s also good to see that there is now consistency across the ERO. When constructing a new plant, final tuning, testing and verifications, and the associated compliance documentation can be completed during the commissioning, which results in activities not needing to be done twice just to generate compliance documentation.

One clarification still to be worked out is the definition of “COD”. This has not yet been defined by NERC. In general terms, it means when construction, testing and commissioning activities are substantially complete, and the generation facility is available for dispatch into the Balancing Area and the market. Also, to be clear, once a generation plant is added to the NERC Compliance Registry, the plant must be compliant from the date of registration. Registered Entities should take care to ensure the registration date and COD are aligned. Keep in mind, this includes new NERC Registry IDs, as well as facilities that are being added to existing NERC registrations.

While this new direction provides entities the flexibility to conduct commissioning and compliance activities more efficiently, entities should not ignore good utility practice. As an example, the Protection System design, coordination, settings and testing should be completed prior to synchronizing to the grid.

NERC is still working on the communications for this guidance on compliance timing, and PCS will continue to monitor this activity. If you have questions regarding NERC compliance timing or other NERC compliance needs, PCS can help. Please contact Dale Zahn at or (262) 436-4116 for further information. To learn more about Proven Compliance Solutions Inc., visit our website at


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