At their monthly meeting April 16, members of NERC’s Standards Committee agreed to post several reliability standards and associated materials aimed at satisfying a FERC directive on inverter-based resources for formal comment and balloting.
The four proposed IBR standards all arise from FERC’s Order 901, issued in 2023, which required NERC to develop standards to improve the reliability of IBRs, including solar, wind, fuel cell and battery storage facilities. (See FERC Orders Reliability Rules for Inverter-Based Resources.) NERC separated its work under the order into four milestones, the second of which concerns data sharing and model validation for all IBRs, whether or not they are registered with NERC. This milestone must be met by November.
Three of the standards were developed by the team for Project 2022-02 (Uniform modeling framework for IBRs):
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- MOD-032-2 — Data for power system modeling and analysis (found on page 52 of the meeting agenda)
- IRO-010-6 — Reliability coordinator data specification and collection (page 94)
- TOP-003-8 — Transmission operator and balancing authority data and information specification and collection (page 113)
Also approved for posting were MOD-033-3 (Steady-state and dynamic system model validation, found on page 21), a product of Project 2021-01 (System model validation with IBRs), and definitions for “model verification” and “model validation” developed by Project 2020-06 (Verifications of models and data for generators).
For all three projects, NERC requested that the SC grant waivers to authorize reducing the normal 45-day comment and ballot periods. In the case of the Project 2022-02 and Project 2021-01 standards, this meant a potential reduction to as few as 30 calendar days; for the Project 2020-06 definitions, the proposed timeline could be as few as 25 days. NERC Director of Standards Development Jamie Calderon explained that the comment periods needed to be shortened so the project teams have time to review comments ahead of a workshop planned for the summer.
Several members warned that setting the comment periods so short could put pressure on industry stakeholders, particularly because all three projects covered similar ground and would require comment from the same set of subject matter experts. Attendees worried the experts might not be able to give each project the time it needed.
To prevent overloading industry, Sean Bodkin of Dominion Energy suggested that NERC post the projects with staggered deadlines. After debate between committee members and NERC staff, the SC eventually agreed to modify the waivers for each posting to allow as few as 25 calendar days for comment on the Project 2020-06 definitions, 35 days for the Project 2021-01 standards and 30 days for the Project 2022-02 standards.
Members also expressed concerns that development on the three projects had proceeded slower than expected, creating the need to shorten commenting timelines. Michael Brytowski, standards specialist at Great River Energy, recalled that NERC held a workshop in January dedicated to the upcoming Milestone 3 IBR projects, and he wondered why the ERO had not been able to post them earlier.
“Back in January … we were looking at a decent amount of time to process this,” Brytowski said. “Now we’re up against the wall with these three projects posted simultaneously. What has happened in that 90 days [since the workshop] that has put us in this position?”
Calderon said that because the three projects were so closely related, the ERO needed “to make sure that [it] put in a robust amount of information,” which required close coordination with all three drafting teams.
“These are complicated projects, [and] coming out of the workshop this January, we did identify that there was a substantive amount of information that we had to consider,” Calderon said. “So all of that was part of what led to the delay here, and [why] it was brought forward in April as opposed to March.”
Updates to CIP, Cold Weather Standards
After dealing with the IBR issues, the SC attended to two more relatively minor standards actions.
First, members voted to approve errata changes to five Critical Infrastructure Protection standards that NERC’s Board of Trustees submitted to FERC in July 2024. (See NERC Sends Virtualization Standards to FERC.) The standards are currently awaiting approval from the commission.
At issue in the CIP standards was the term “electronic access control and monitoring system” (EACMS), which NERC Manager of Standards Development Alison Oswald explained should have been written with an “or” instead of “and” to match the definition that Chair Todd Bennett, of Associated Electric Cooperative Inc., noted has been in NERC’s Glossary of Terms “for quite some time now.”
The committee approved correcting the submitted standards, which will require a supplemental filing to FERC but not any further industry comment or ballot.
Finally, the SC voted to accept a standard authorization request for a project that will revise EOP-012-3 (Extreme cold weather preparedness and operations), which NERC recently submitted to FERC. This project will focus on tweaking the standard from a Canadian perspective “to reflect the geographical differences” between Canada and the U.S., and the varying regulatory frameworks between Canadian provinces.
The SC agreed to authorize posting of the SAR for a 30-day formal comment period and to authorize solicitation of members for the drafting team. Oswald explained that NERC “would specifically be soliciting for Canadian members” for the team.