Inverter-Based Resource (IBR) Registration Initiative
The Federal Energy Regulatory Commission (FERC) issued an order in 2022 directing the North American Electric Reliability Corporation (NERC) to identify and register owners and operators of currently unregistered inverter-based resources (also known as “IBRs”) that are connected to the bulk power system (BPS). The purpose of this initiative is to close an identified reliability gap with IBRs connected to the BPS that have a material impact on the BPS but are unregistered and therefore not subject to the NERC Reliability Standards.
NERC is addressing the risk by requiring candidates who own and/or operate non-BES inverter-based generating resources that have an aggregate nameplate capacity of greater than or equal to 20 MVA delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV to register with NERC.
ReliabilityFirst is one of six Regional Entities that work alongside NERC as part of the Electric Reliability Organization (ERO) Enterprise. Together, along with partners in the electric utility industry and other stakeholders, we are working to identify and register all of these unregistered IBRs that are connected to the BPS by 2026 as part of an official work plan approved by FERC. In the ReliabilityFirst footprint, the most common types of IBRs include solar, wind and battery energy storage systems. For more details on this regulatory structure, click here.
For the latest updates on this initiative, see the NERC Quick Reference Guide and follow our LinkedIn. Questions related to this initiative? Please reach out to ReliabilityFirst’s Registration department via our Contact Us page.
See how the initiative will work
This video produced by NERC highlights:
- How IBRs fit into the big picture of electric grid reliability and why these entities need to be registered
- The history behind this initiative, including the FERC order directing it
- How NERC plans to identify, educate, and register currently unregistered IBRs
- What unregistered IBRs should expect, including the registration process, their compliance obligations, and timeline
Latest updates
Inverter-Based Resource Registration Initiative updates from NERC include the following:
Registration
- ERO Enterprise Registration staff are completing the validation of the responses received from the July 8, 2024 Request for Information (RFI) to all registered Balancing Authorities and Transmission Owners to identify owners and operators of IBRs connected to the bulk power system in their footprints that meet the new Generator Owner and Generator Operator Category 2 criteria.
- A second phase of the identification and validation process was started in December via information requests to candidate Category 2 Generator Owners and Generator Operators seeking specific facility and entity data for assessment and to prepare qualifying entities for Registration. This process will continue into early 2025.
- To assist the Regional Entity assessment process, an ERO Enterprise Practice Guide on the application of the new Category 2 Registration Criteria is under development and is anticipated to be published in Q1 2025.
- Please see the documentation required to register new Generator Owner (GO) and Generator Operators (GOP) functional entities in ReliabilityFirst (RF) Region.
Standards
- NERC continues to develop new and modified Reliability Standards related to the IBR Registration Initiative as well as FERC Order No 901. NERC staff maintains an up-to-date
project list on the Standards Under Development page, which includes indicators for projects that are associated with IBR, Distributed Energy Resources (DER), and Order 901. - NERC’s Order No. 901 work includes three standards projects, each of which had their own pre-existing scope of work. NERC recommended assignment of the Milestone 3 Standard Authorization Requests to these existing teams, with the relevant subject matter expertise, and standards already under revisions, to allow for a more expedited process. Each drafting team will
develop Implementation Plans similar to those produced for Milestone 2 projects, specifically accounting for non-BES IBR (Category 2 generation). Industry is encouraged to continue to follow how these projects will address IBRs and these new registrations.
Stakeholder Outreach and E-ISAC Engagements
- The ERO Enterprise hosted an IBR Registration Initiative webinar for new registrants on Nov. 13, 2024. The webinar recording is available here and the presentation slides are posted here.
- The E-ISAC wrapped up 2024 IBR engagements with panelist participation at GameChange Solar, SolarConnections conference in New York City in December, highlighting how solar asset owners can efficiently strengthen their cyber security posture through E-ISAC programming, information sharing, and industry engagement.
- The E-ISAC also participated in the November ERO Enterprise webinar and looks forward to additional engagements with the renewable energy sector to continue contributing industry insights and opportunities to collaborate.
Legal
- On Nov. 4, 2024, NERC filed with FERC a set of proposed Reliability Standards and associated definitions responsive to FERC Order No. 901. These filings included the:
- The proposed Reliability Standards address Order No. 901 directives related to disturbance
monitoring data sharing, IBR performance requirements, and post-event performance validation for registered IBRs, and represent the completion of work under Milestone 2 of NERC’s Order No. 901 work plan. - On Nov. 7, 2024, NERC filed a registration work plan progress update with FERC.