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Regulatory Updates

NERC Seeks to Improve GADS Reliability Performance Reporting

Steve Persutti | July 13, 2021

Under the enabling legislation that created the Electric Reliability Organization, NERC is responsible for assessing the reliable performance of the power system. One way NERC does so is via an industry reporting system for generation and transmission. The Generator Availability Data System (GADS) has been used by NERC and the industry for over 40 years to obtain data on the generation component of the power system[1].

Due to the rapidly changing generating resource mix, it is essential that NERC have comprehensive plant, event, outage and performance data for photovoltaic and wind generation to ensure reliability. As renewable technologies are increasingly deployed, a complete set of generation asset performance statistics is necessary to allow NERC to evaluate the system’s ability to serve load, the performance of the power system and to forecast any potential reliability issues due to resource inadequacy.

Therefore, NERC is proposing to make the following enhancements to the GADS data collection process for renewable generation:

  • Add Generator Owners that operate solar photovoltaic facilities of 20 MW or greater to the Generating Availability Data System (referred to as “GADS-PV”); and
  • Expand GADS Wind (“GADS-W”) reporting to include connected energy storage and event reporting.

These changes are required for NERC’s performance analysis to help:

  • Model renewable generation performance for Reliability Assessments and implementing Loss‐of‐load Expectation studies.
  • Analyze how resource availability and performance of renewable generation impacts Planning Reserve Margin calculations.
  • Examine potential refinements to the NERC severity risk index performance scoring system using actual renewable generation performance data to establish the effect that the presence of renewable generation is having on Event Driven and Condition Driven reliability risks.

Your company may already be preparing a response to the request for comments related to these changes, which closes on July 31, 2021. It is expected that industry comments will be incorporated into the proposed GADS data collection changes and then submitted to the NERC Board of Directors for approval. As currently proposed, the new reporting requirements would go into effect on January 1, 2023.


Next Steps

TRC closely follows industry regulatory trends including the expansion of data collection efforts by NERC. If your company is a generation owner that is planning to implement renewable resources, it will be impacted by these proposed GADS data reporting requirements. We recommend that you review the proposed data reporting changes and additions. Consider submitting comments to NERC if you have any by July 31, 2021.

[1] Under its FERC authorized Rules of Procedure (section 1601), NERC or Regional Entity Request for Data or Information Within the United States, NERC and Regional Entities may request data or information that is necessary to meet their obligations under Section 215 of the Federal Power Act, as authorized by Section 39.2(d) of the Commission’s regulations, 18 C.F.R. § 39.2(d). The provisions of Section 1600 do not apply to Requirements contained in any Reliability Standard that call for the provision of  data or information. In those instances, the Requirements in the Reliability Standards govern. Under rule 1603- Owners, Operators, and Users to Comply, owners, operators, and users of the Bulk Power System registered on the NERC  shall comply with authorized requests for data and information.

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

Steve Persutti

Steve Persutti is TRC’s Senior Vice President of Business Development. He has 25 years of comprehensive management experience within the energy industry and a consistent and successful record in strategic business planning, productivity and efficiency improvements, systems design and implementation, and employee collaboration. His areas of expertise include engineering management, project management, EPC project management, construction management, financial analysis and customer service. Steve has an M.B.A in Finance from the University of Hartford and a B.S. in Marketing from the University of Connecticut. Contact Steve at

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