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Regulatory Updates

NERC Files Comments in the FERC Generator Interconnection Notice of Proposed Rulemaking

Jim Whitaker, PE | November 21, 2022

The North American Electric Reliability Corporation (NERC) and its regional organizations have jointly filed comments in FERC’s Generator Interconnection Rulemaking Case.1  The rulemaking addresses improvements needed to reliably facilitate the power industry’s transition to renewable and distributed generating resources utilizing inverter-based technologies.

NERC and its regional organizations requested that FERC:

  • Modify the Large and Small Generator Interconnection Agreements and Procedures to require:
    • Model validation with actual installed equipment prior to interconnection
    • A “true-up” of modeling and studies to address any discrepancies between what was studied and what is installed.
    • Inclusion of electromagnetic transient (“EMT”) studies to ensure accurate modeling of nonsynchronous inverter-based generation control systems.
  • Modify the Large and Small Generator Interconnection Agreements and Procedures to incorporate certain elements of NERC Reliability Guidelines related to inverter-based resources.
  • Enact enhancements to increase the efficiency and effectiveness of the interconnection queue.

NERC’s filing implements a portion of its recently released Inverter-Based Resource Strategy relating to interconnection process improvements that address changing technology. This is one of the key components of NERC’s efforts to maintain and improve power system reliability.

As the case unfolds, TRC’s clients need to be aware of changes to interconnection processes and system study requirements that a final rule will likely create. The addition of EMT studies, true up studies, and model validation will place stress on utilities who are already stretched thin due to system planning and human resources constraints, including current simulation knowledge and capabilities.

Next Steps:

Utilities are encouraged to review the NERC comments to FERC and the associated reference documents in detail to understand the implications of the proposals advocated by NERC regarding interconnection processes. NERC’s input will likely have a strong influence on FERC’s ultimate decisions, which will impact processes, internal controls, and human resources’ skill sets within your company. If you conclude that your company needs supplemental technical assistance, TRC subject matter experts have the skills and experience to meet the future planning and operations obligations. The rulemaking will likely expand the obligations of interconnecting utilities to examine, evaluate, plan, and operate your company’s portion of the changing power system to a greater level of rigor.

TRC has performed more than 600 transmission and distribution planning studies to analyze the power system interconnection impact of wind, solar, storage, combined-cycle gas, biomass fueled, and hydro-electric generators. TRC’s Systems Studies experts have the necessary expertise in traditional power flow and dynamic analysis including the new transient analysis studies being demanded for the successful integration of IBR.


NERC Comments in the FERC Generator Interconnection NOPR

TRC Regulatory Update: NERC Releases Inverter-Based Resource Strategy Plan

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TRC closely follows the national and state regulatory trends in all regions of North America. Our approach to power system 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 engineering, planning and operations, TRC supports public utilities and private energy providers in their effort to stay ahead of the 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 developments to help you achieve your company’s business goals.

1 FERC Docket No. RM22-14-000 – Improvements to Generator Interconnection Procedures and Agreements

Jim Whitaker, PE

Jim Whitaker, PE is Supervisor of Power Systems Studies at TRC. He has over 30 years of experience in Transmission and Distribution Planning, and Substation, Transmission and Distribution Engineering. His Transmission Planning projects include coordinating joint/regional 10-year transmission plans, generator interconnections, regional system assessments, as well as NERC compliance studies. His projects have included studies for both Utilities and Project Developers across the United States in the Eastern and Western Interconnection transmission systems as well as ERCOT. Prior to joining TRC, Jim worked for Xcel Energy, Peak Power Engineering, Tucson Electric Power and Virginia Power. Contact Jim at

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