NERC Clarifies PRC-029 Implementation Timeline and Enforcement Discretion

With the rollout of PRC-028, PRC-029, and PRC-030 standards for IBRs, one of the most frequently asked questions we receive is the implementation timeline for PRC-029.

There has been confusion throughout the industry about where “implementation” falls within the “design and operate” language. NERC helped clear up this confusion in a recent Small Group Advisory Session (“SGAS”) on August 10.

Background

As a quick recap, the majority of existing BES IBRs are expected to have settings designed by 10/1/2026 (1/1/2027 for non-BES IBRs).

Instead of separating design and implementation, NERC’s SGAS reiterated that 10/1/2026 is the deadline for both design and implementation.

Realizing that this poses operational challenges at multiple levels, NERC has recognized that Enforcement Discretion is needed for many entities that may not be able to meet design deadlines.

Enforcement Discretion

NERC has instructed Regional Entities to use enforcement discretion for the implementation of PRC-029 ride-through settings.

This is aimed at entities that have been unable to secure the resources necessary to get settings installed and configured in the field by the compliance date, citing:

• OEM, vendor, and contractor availability
• Equipment installation
• Outage scheduling
• Approvals needed from outside or planning entities

USV Advice

1. Engage your Region early. Your Region determines whether the enforcement discretion applies to your circumstances. The ERO Enterprise is evaluating entity-specific circumstances, and NERC has directed Registered Entities to contact their Regional Entity to discuss specifics.
2. Build and keep your evidence file immediately. NERC expects entities to retain documentation of progress toward scheduling and implementing the settings — the schedule developed with your OEM, email chains, and other communications showing the effort made and the inability to secure resources. This is validated later through routine monitoring rather than submitted in advance.

This information has been formalized through a CMEP Practice Guide that NERC posted here.

If you’d like more guidance on the new PRC standards for IBRs, as well as next steps for submitting exemptions to your Regional Entity, reach out to USV. We are here to help maintain full compliance with all existing and new standards for Category 1 and Category 2 Inverter-Based Resources.