Historically, Inverter-Based Resources (IBRs) under 75 MW were excluded from the Bulk Electric System (BES) Definition. Recently, FERC directed NERC to remove the 75 MW floor on the BES I4 Inclusion. This means that any inverter-based resources that can impact the BPS will need to be NERC registered. Within 90 days, NERC is to develop the criteria that will be used to register these new entities and the Reliability Standards that would apply. This may entail the addition of a new functional registration and require new or revised Reliability Standards.
The draft order directs NERC to do three things.
- Complete modifications to its registration processes no later than 12 months after Commission approval of the work plan.
- Identify all owners and operators of BPS-connected IBRs that in the aggregate affect the reliable operation of the Bulk-Power System no later than 24 months of Commission approval of the work plan.
- Register owners and operators of Bulk-Power System-connected IBRs that in the aggregate have a material impact on the reliable operation of the Bulk-Power System no later than 36 months after Commission approval of the work plan. The draft order recognizes that smaller Bulk-Power System-connected IBRs may not present the same reliability impact in all circumstances as generation that has historically been registered. Accordingly, the draft order acknowledges that NERC may determine that the full set of Reliability Standard Requirements otherwise applicable to generator owners and operators need not apply to all newly registered Bulk-Power System-connected IBR generator owners or operators.
To access a copy of NERC’s recently filed Work Plan, go to: https://www.nerc.com/FilingsOrders/us/NE
PCS is closely following these developments and providing information and guidance to our clients. For information on how we can support your organization’s NERC Reliability Standards compliance needs, please contact Dale Zahn at (509) 504-5496 or visit our website at www.provencompliance.com.