NERC has submitted for FERC approval new compliance criteria for the registration of IBRs as part of continuing efforts to address reliability risks. It is critical for renewable energy developers, generation owners and transmission owners to understand the potential implications for interconnection studies and interconnection queues.
As explained in its filing, NERC is proposing to update the Generator Owner and Generator Operator (“GO” and “GOP”) Registry Criteria to include a new category (“Category 2 GOs” and “Category 2 GOPs”) of entities that own or operate non-BES inverter based generating resources that:
Either have or contribute to an aggregate nameplate capacity of greater than or equal to 20 MVA, or
Connected through a system designed primarily for delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV.
Drivers for the Change
For several years, the ERO Enterprise has been publicly identifying the impact on reliability associated with the transformation of the generating resource mix, resulting in the increased integration of IBRs.
In the opinion of FERC and NERC, these assessments have adequately demonstrated a change in long-held assumptions regarding the reliable operation of the power system. If not prudently managed, the accelerated integration of IBRs will create new technical interoperability challenges that pose a risk to reliability. As a precautionary measure, NERC issued its IBR Strategy and explained:
“The speed of this change continues to challenge grid planners, operators, protection engineers, and many other facets of the electricity sector. Implemented correctly, inverter technology can provide significant benefits for the BPS; however, the new technology can introduce significant risks if not integrated properly. Based on recent analysis, these are high impact and high likelihood events that require substantive action by the ERO as called out by the NERC Framework to Address Known and Emerging Reliability and Security Risks (NERC Risk Framework).”
The NERC Inverter-Based Resource Strategy is a four pillared plan to address these technical issues and reliability needs. One pillar is to pursue enhancements to the regulatory model under section 215 of the Federal Power Act which includes the NERC registration criteria.
NERC’s approach is reflected in the Quick Reference Guide, IBR Strategy, and indicated that 16% of materially impactful IBRs are currently not subject to registration and compliance with NERC Reliability Standards as they are non-BES IBRs.
Given the proposed registration criteria and the applicability of compliance requirements related to IBRs in the interconnection queue, it is critical for TRC clients to plan ahead and make adaptations to their interconnection study process.
FERC Approval may be expedited
NERC is seeking FERC’s expedited approval for the compliance registry criteria, given the many challenges it helps mitigate. An approval order from FERC may be issued relatively quickly.
Next Steps:
TRC Can Help
TRC has expertise in power generation, protection and controls, and power delivery engineering and can complete an independent review of your company’s power reliability performance of IBRs.
We can help your company meet the coming requirements in this area of focus and expediting your reliability risk mitigation and NERC compliance efforts.