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Regulatory Update

FERC Order 901 Calls for Standards to Address IBR Reliability Gaps

Deepika Mothkuri, EIT | November 27, 2023

As the power delivery system continues to rapidly evolve due to federal and state decarbonization policy initiatives, Inverter Based Resources (IBRs) are playing central role when it comes to adding new electric generation capacity into the bulk power system (BPS).

To address reliability gaps related to IBR technology in Solar, Wind and Battery Energy Storage applications, FERC has recently issued Order No. 901.  Order No. 901 directs NERC to develop new or modified standards that require owners and/or operators to provide accurate data related to facility performance when connected to the BPS.  FERC noted that such data is necessary to apply accurate system models so interconnecting utilities can successfully plan, operate and analyze performance of IBRs.

FERC Order No. 901 documents the poor reliability performance of IBRs since 2016 and outlines the reliability gaps that have been detected broadly within four key areas:

  • Data sharing
  • Model validation
  • Planning and operational studies
  • Performance requirements

As noted in TRC’s previous Regulatory Update on the NERC IBR Webinar Series, NERC has been providing educational resources to help industry technical experts navigate this complex issue.  Additionally, NERC released an FAQ document covering the general themes identified in the more than 1,000 comments and questions received throughout the series.

Deadlines and Requirements for the IBR Standards Development Process

NERC must submit an informational filing within 90 days of the issuance of Order No. 901, including a detailed and comprehensive standards development plan that demonstrates how NERC will prioritize the development of new or modified Reliability Standards to meet the following deadlines over the next three years:

  • By November 4, 2024, NERC must submit new or modified Reliability Standards that establish IBR performance requirements:
    • Addressing frequency and voltage ride-through performance
    • Post-disturbance ramp rates
    • Phase lock loop synchronization limitations
    • Known causes of IBR tripping and momentary cessation of IBR output
  • By November 4, 2025, NERC must submit new or modified Reliability Standards addressing:
    • Data sharing for registered IBRs, unregistered IBRs, and IBR-Distributed Energy Resources (IBR-DERs) in the aggregate
    • Data and model validation for registered and unregistered IBRs and IBR-DERs in the aggregate
  • By November 4, 2026, NERC must submit new or modified Reliability Standards addressing planning and operational studies by requiring:
    • Transmission owners to provide to Bulk-Power System planners and operators modeling data and parameters for unregistered IBRs in their transmission owner areas that, individually or in the aggregate, materially affect the reliable operation of the Bulk-Power System.
    • Distribution providers to provide to Bulk-Power System planners and operators modeling data and parameters for IBR-DERs in the aggregate in their distribution provider areas where the IBR-DERs in the aggregate materially affect the reliable operation of the Bulk-Power System.

Next Steps

In its Order FERC stated that NERC should use its discretion to identify the appropriate technical requirements needed to ensure frequency and voltage ride through by registered IBRs during the future standards development process. TRC clients should be aware that NERC has the discretion to consider incorporating or referencing other standards, for example IEEE 2800-2022 – Standard for Interconnection and Interoperability of Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems.

To stay ahead of reliability risk issues and the FERC mandated compliance obligations, TRC recommends that utility compliance managers and system planning and interconnection study personnel review the FERC Order No. 901 and assess the implications of the FERC directives to NERC mandatory standards in light of their company’s functional registration(s).


FERC Order No. 901


IBR related system disturbances Event Report list

TRC Services – System Studies

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TRC closely follows the national, provincial, and state regulatory trends in all regions of North America. Our approach to power system security, engineering, planning, design, construction and commissioning testing, balances solutions that incorporate industry reliability risk trends, mandatory reliability standard requirements, regulatory guidance, compliance obligations, best practices, operational goals and budgets. With expertise in power system planning, engineering and operations, TRC supports public utilities and private energy providers in their efforts to stay ahead of the regulatory curve and to meet or exceed regulatory requirements as they evolve.

This regulatory update is provided as a service to TRC’s utility clients, helping to keep you informed of forward-looking issues that will impact your company’s electric system reliability risks along with related topics regarding regulatory development, to help you achieve your company’s business goals.

Deepika Mothkuri, EIT

Deepika Mothkuri is a Supervisor of Power System Studies at TRC. She has 15+ years of experience in the electric utility industry with an expertise in power system planning, design and analysis and use of a variety of software tools.  She has hands-on transmission and distribution planning and project engineering experience with both public and private sector clients including American Electric Power, El Paso Electric and NY- ISO.  Deepika has an MS in Electrical Engineering from New Mexico State University and a B.Tech. in Electrical & Electronics Engineering from JNT University, India.

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