Powering Strong Communities

Federal Energy Regulators Approve NERC Work Plan Tied to Inverter-Based Resources

The Federal Energy Regulatory Commission on May 18 approved a work plan submitted by the North American Electric Reliability Corporation related to inverter-based resources.

In the order, FERC approved the work plan filed by NERC in compliance with FERC’s November 17, 2022, order requiring NERC to develop a work plan to identify and register owners and operators of IBRs connected to the bulk power system that are not currently required to register with NERC but that, in the aggregate, have a material impact on the reliable operation of the BPS. 

In the work plan, NERC proposed to modify its rules of procedure to include a new registered entity function composed of owners of IBRs interconnected to BPS. 

The work plan reflected initial parameters for this new class of entity that owns/operates IBRs. 

Specifically, the function would include IBRs that: (1) have an aggregate nameplate capacity of less than or equal to 75 MVA and greater than or equal to 20 MVA interconnected at a voltage greater than or equal to 100 kV; and (2) have aggregate nameplate capacity of greater than or equal to 20 MVA interconnected at a voltage less than 100 kV.  NERC also offered a timetable for identifying and registering these IBR owners and operators.

The American Public Power Association, Edison Electric Institute, Large Public Power Council, and Transmission Access Policy Study Group filed joint comments on the work plan, expressing general support for NERC’s approach. 

The groups urged FERC, however, to refrain from accepting particular registration thresholds or language set out in the work plan, given its preliminary nature and the need for further NERC stakeholder discussion on important issues raised by NERC’s proposal. 

They also argued that NERC’s timetable omitted a number of necessary steps, including an allocation of time to revise NERC reliability standards to address the expanded registration of IBR owners and operators. The groups also cited the need to revise NERC’s definition of the Bulk Electric System, given the inextricable link between the BES definition and NERC’s registration criteria.

In the order, FERC approves the work plan and timetable. 

The order also addresses a number of issues raised by the trade groups and other commenters. For example, FERC confirmed that it is “not making a determination on the substance or direction of the registration approach that NERC will develop.”

The Commission said that it “appreciate[s] that commenters, both supporting and opposing NERC’s work plan, raise various issues regarding the potential approach, scope, and detail of NERC’s IBR registration plan. We decline to address these matters in this order.” 

FERC said that it will address such substantive issues when NERC formally files to implement its proposal, and, in the meantime, the Commission urged interested parties to raise any concerns in the NERC stakeholder process.

However, contrary to the position of APPA and the other groups, FERC declined to require NERC to consider changes to the BES definition as part of the work plan. The Commission also rejected the groups’ position that the work plan timeline should be modified to provide time for reliability standard revisions.