NERC recently filed rule changes with FERC that propose to significantly expand NERC registration and compliance requirements to inverter based resources, such as renewable energy and battery facilities, that historically were too small to be subject to such requirements.  NERC’s proposed rule changes are one of the latest developments in NERC’s multi-year effort to address the “reliability gap” associated with these types of resources.

NERC’s proposal includes revisions to the NERC Rules of Procedure to update the Generator Owner (“GO”) and Generator Operator (“GOP”) registry criteria to include an expanded category of smaller resources, which NERC has labeled Category 2 GOs and Category 2 GOPs.  NERC initially called these entities “GO-IBRs” but stakeholders found that term confusing so NERC changed the term to Category 2 GOs/GOPs. Under NERC’s proposal, Category 2 GOs/GOPs include non-bulk electric system inverter based resources that (i) either have or contribute to an aggregate nameplate capacity of greater than or equal to 20 MVA, (ii) connected through a system designed primarily for delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV. If an entity meets the criteria for Category 2 GO or Category 2 GOP, once registered, it would be required to comply with associated reliability standards.