Industry Input Sought on Exemption Volume and Impact of New Standard
On November 5, 2025, the North American Electric Reliability Corporation (NERC) will host a Virtual Technical Conference to address open issues stemming from FERC Order No. 909, which approved the new Reliability Standard PRC-029-1 on ride-through requirements for Inverter-Based Resources (IBRs).
The technical conference will focus on:
- Clarifying the evidence requirements for legacy IBR equipment seeking exemption from PRC-029-1
- Evaluating how to account for equipment limitations of HVDC-connected IBRs with choppers
- Addressing concerns related to the long lead times between IBR design decisions and actual in-service dates
NERC is calling on industry stakeholders to participate and provide input to better understand the scope and impact of potential exemptions and to help shape any future clarifications or modifications to the standard. For more information on the technical conference and participation, review the NERC announcement here.
Background: FERC Approves PRC-029-1 with Exemption Framework
On July 24, 2025, the Federal Energy Regulatory Commission (FERC) issued Order No. 909, officially approving:
- PRC-029-1 – Ride Through Requirements for Inverter-Based Resources (IBRs)
- PRC-024-4 – Frequency and Voltage Protection Settings for synchronous generators, Type 1 and 2 wind resources, and synchronous condensers
- The formal definition of the term « Ride-through »
Order No. 909 directs NERC to determine how PRC-029-1 should accommodate:
- The hardware limitations of certain IBRs, particularly HVDC-connected units with choppers
- The time lag between the design and commissioning of new IBRs, given that many projects initiated today may not be in service within 12 months of the order’s approval
FERC also asked NERC to explore how to modify PRC-029-1 to better define acceptable forms of evidence for demonstrating when legacy equipment cannot comply with the new ride-through requirements.
Exemption Provision and Informational Filing Requirement
PRC-029-1 contains an exemption provision allowing existing (legacy) IBRs already in operation at the time the standard becomes effective to request an exemption from ride-through requirements, if compliance would necessitate hardware replacement.
In response, FERC is seeking clarity from industry on:
- The anticipated volume of such exemptions
- The situations in which entities may invoke the exemption
- Any potential impact on the effectiveness and reliability outcomes of PRC-029-1
NERC must submit an informational filing to FERC 18 months after the end of the exemption request period (as defined in Requirement R4 of the standard), detailing the reliability impacts of all granted exemptions.
Next Steps: TRC Can Help
TRC is actively monitoring the implementation of PRC-029-1 and the evolving regulatory guidance from FERC and NERC. Our NERC compliance and system planning experts are available to help your organization prepare for the November 5th conference, understand the exemption process, assess legacy equipment eligibility and develop compliance strategies tailored to your system’s needs. Contact us to learn more today.
Resources
FERC Order #909 – Approving Ride Through Standards
FERC Order #909 – Approving Ride Through Standards July 24, 2025
NERC Order #909 Virtual Technical Conference Announcement
November 11, 2025
Power System Studies
March 2025
TRC NERC Compliance Services
Publié
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This regulatory update is a service to TRC’s utility clients, helping keep you informed of issues that impact your company’s electric reliability risks along with related topics regarding future regulatory developments to help you achieve your company’s business goals including compliance with NERC standards.
