On November 17, 2022, FERC issued three orders intended to address the reliability impacts of the rapid integration of inverter-based resources (“IBR”), including solar, wind, fuel cell, and battery storage resources, in Bulk-Power System. (“BPS”). Specifically, in the first proceeding, FERC directed the North American Electric Reliability Corporation (“NERC”) to develop a plan to register entities that own and operate IBRs so that NERC can monitor their compliance with the Reliability Standards of NERC. In the second proceeding, FERC issued a Notice of Proposed Rulemaking (“NOPR”) to direct NERC to develop new or revised Reliability Standards that address reliability gaps related to IBRs. Finally, in a final proceeding, FERC approved revisions to two of NERC’s Reliability Standards.
In the first proceeding, in Docket No. RD22-4, FERC directed NERC to develop and submit a work plan to identify IBR operators connected to BPS but not yet registered with NERC under the definition of bulk electric system (“BES”) and that had an “aggregate, material effect on the reliability operation” of BPS. The BES identifies the elements, and groups of elements, required for reliable BPS planning and operation. The BES definition establishes a standard to identify all elements of “transmission”; especially, those operating at 100 kV or higher. The 100 kV threshold is used for real and reactive power resources. As recognized by FERC, most of the newly interconnected IBRs connect voltages below 100 kV or have capacities below 75 MVA, and thus do not meet the minimum size criteria under the BES. meaning. FERC noted that it issued the order because the reports indicated the potential for IBRs, in general, to have a material impact on the reliability of BPS operations. FERC regulations require every BPS user, owner, and operator to register with NERC and comply with its Reliability Standards. FERC noted that the work plan should detail how NERC plans to identify and register owners and operators who are not currently required to register with NERC under the BES definition but are connected to the BPS.
In the second proceeding, in Docket No. RM22-12, FERC issued a NOPR to direct NERC to develop Reliability Standards for IBRs that include data sharing, model validation, planning and operational studies, and performance requirements. FERC also proposed to direct NERC to submit a compliance submission within 90 days of the final effective date of the rule containing the plan, which must include a detailed, comprehensive development plan and standards implementation to ensure that all new or revised Reliability Standards identified in the final rule are submitted to FERC within 36 months of plan approval. FERC noted that while IBRs provide many benefits, they also raise new considerations for transmission planning and BPS operations. Initial comments on the NOPR are due 60 days after the date of publication in the Federal Register, and response to comments are due 90 days after that.
In the final proceeding, in Docket No. RD22-5, FERC issued an order in response to a petition filed by NERC on June 14, 2022, in which NERC seeks to amend FAC Reliability Standards FAC-001-4 (Facility Interconnection Requirements) and FAC-002-4 (Facility Interconnection Studies). In its petition, NERC requested that FERC approve the associated violation risk factors and violation severity levels in the proposed implementation plan and the retirement of the effective versions of the FAC Reliability Standards. FERC approved NERC’s proposed revisions, noting that they improve upon the existing FAC Reliability Standards. FERC also found that the proposed Reliability Standard FAC-002-4 Requirement R6 would avoid potential disputes over changes to facilities by allowing the planning coordinator to define the term “eligible change” and requiring public input. post definition. In addition, FERC approved the proposed implementation plan based on it providing a reasonable time for entities to comply with the new requirements. FERC further approved NERC’s proposed clarification of the current violation risk factors and violation severity level assignments for these FAC Reliability Standards.
You can find a copy of the orders mentioned above here: Docket No. RD22-4, Docket No. RM22-12, and Docket No. RD22-5.
