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Regulatory Update

NERC Releases 2024-2026 Standards Development Plan

NERC has submitted its 2024-2026 Reliability Standards Development Plan to the Federal Energy Regulatory Commission (FERC), outlining its current priorities and future standard development plans to protect the reliability of the Bulk Power System over the next three years.

This plan provides a new structure for categorizing the relative importance and priorities of NERC’s standards development projects. It is designed to address the high reliability risk issues earliest in the three-year period. The 2024 Plan report provides a status update on active development projects and a forecast of future work to be undertaken by NERC, and its stakeholders throughout the upcoming years. The informational NERC filing includes a progress report comparing results achieved to the prior year’s Reliability Standards Development Plan.

Risk Priorities

Unlike past reports, a new prioritization approach has been taken for this plan. Each new or continuing Reliability Standard Project identified in the 2024 – 2026 Development Plan has been assigned a priority of either high, medium, or low. According to the NERC filing these assignments are based on the following criteria:

  • Outstanding regulatory directives with filing deadlines (high priority);
  • NERC Reliability Issues Steering Committee (RISC) category rankings of high impact with consideration of probability of occurrence (high or medium priority);
  • Potential reliability risks identified through feedback mechanisms (high, medium, or low priority, based on the risk);
  • Outstanding regulatory directives without regulatory deadlines or regulatory considerations (high or medium priority);
  • Outstanding requirements that are known candidates for retirement (medium or low priority); and
  • Any known adverse content and quality assessment (likely low priority)

Next Steps

Industry stakeholders, including This proactive step will help prepare your organization for a very active standards development, balloting, and comment period in the next three years.

Detailed modifications to the standards requirements and NERC evidence production will impact your company’s compliance obligations. The standards requirement changes will necessitate that your company review its policies, procedures, and operational guidelines.  Accordingly, it is important to review your internal controls program and any automated processes for generating compliance evidence in preparation for your next NERC/Regional Compliance audits.

Selected High Priority Projects

There are twelve high priority projects. The most noteworthy of the high priority projects are:

  • Project 2020-02 Modifications to PRC-024 (Generator Ride-through) with drafting estimated to be completed by May 2024.
  • Project 2021-07 Extreme Cold Weather Grid Operations, Preparedness, and Coordination with drafting estimated to be completed in two phases over 2022-2024; the first phase was completed in September 2022. Phase 2, standards EOP-011-4 and TOP-002-5 was completed in October 2023, Phase 3, EOP-012-2, is expected to be completed by February 2024.
  • Project 2023-02 Performance of Inverter Based Resources with drafting estimated to be completed by October 2024.

To stay ahead of reliability risk issues, the reliability standards development efforts, and additional mandated compliance obligations, TRC recommends that you also review this plan in detail. The upcoming program NERC is implementing will require significant time and technical resource to stay engaged and aware of to maintain compliance. Your company subject matter experts (accountable for technical understanding, review, and compliance verification with various NERC standard requirements) may need additional support as the NERC program evolves.

Resources:

NERC 2024 -2026 Reliability Standards Development Plan

NERC_Solutions_for_Transmission_Development_Projects

NERC_Compliance_Solutions_for_Registered_Distribution_Providers

Your Trusted Regulatory Advisor

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 developments, to help you achieve your company’s business goals.

Dwayne Stradford

Dwayne Stradford serves as TRC’s NERC Compliance Director in the Power Division.  He is leading and coordinating TRC’s NERC compliance support services with our various power utility clients.  He is an accomplished, diverse energy professional with over 29 years of engineering experience regarding real-time transmission operations, short/long term transmission planning, NERC Reliability Compliance Standards (both NERC-CIP and NERC O&P), Transmission Reliability Assurance, utility scale renewables integration, FERC Regulatory/RTO policy, and Project Management.  He spent the bulk of his career (close to two decades) working for AEP, but has considerable working experience in the electric utility industry as a professional consultant.  He has worked with utility clients on transmission and generation related projects in all three interconnections, so he has breadth of regional BES experience throughout the entire country. Please contact Dwayne Stradford for more information.

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