Background
Traditionally, generating resources, including traditional generation and IBR resources, required to register with NERC were those who met the Bulk Electric System (BES) definition criteria by being connected at 100kV or higher, with a single generator at or above 20 MVA, or aggregate generation at or above 75 MVA. However, the ERO enterprise (NERC and its Regional Entities) identified a reliability gap caused by the increasing levels of Inverter-Based Resources (IBRs) that did not meet the BES definition and therefore are not required to meet the current Standards. Due to the identified gap, NERC expanded the registration criteria for Generation Owners (GO) and Generation Operators (GOP) to include certain IBRs that do not meet the BES definition. This new set of registered IBRs are often referred to as “non-BES IBRs”, “category 2 generation” or “category 2 IBRs”.
How does this impact me?
Entities that own category 2 generation will now be registered with NERC as a Generation Owner and/or Generation Operator if the IBR generation:
- Contribute to an aggregate nameplate capacity of 20 MVA or greater,
- The ownership of the IBR resources is not a factor in determining the “contribution”. For example, Company A may own an 18 MVA wind farm, Company B may own a 1 MVA solar site and Company C may own a 1 MVA battery energy storage system (BESS). In this case, all three sites would meet this portion of the registration criteria.
- connected through a system designed primarily for delivering such capacity to a common point of connection
- IBR resources that are connected to a system that is primarily designed to distribute electricity, would not meet this portion of the criteria.
- at a voltage greater than or equal to 60kV.
For these new registrants, the IBR registration initiative involves three key components: Registration, Reliability Standards, and Compliance Monitoring and Enforcement Program (CMEP).
If you own IBRs that meet this new criteria, the regional entities (MRO, NPCC, RF, SERC, TexasRE, WECC) that support the NERC CMEP may have already contacted you. The regional entities were reliant upon publicly available information when identifying IBRs that meet this new criteria. This leaves the possibility that owners of applicable IBRs have not been contacted yet. If you are unsure, please contact us and we can help you determine if you have any IBRs that are required to be registered.
What do I have to do if I have category 2 IBRs?
NERC and the regions are still in the process of identifying and registering these IBRs in the NERC program, which is expected to conclude by May 2026. NERC has identified eight (8) existing Reliability Standards that will become effective on the later of your registration date or May 16, 2026. Furthermore, there are three (3) additional standards that have recently been modified and approved by FERC to become effective in 2026 as well. Beyond these standards, NERC has identified 26 that need to be modified to apply to category 2 IBRs. As such, compliance deadlines for these additional Standards are unknown at this point. Utility Services will continue to monitor these development projects and be available for advice and support as information becomes available.
So, what will you have to do if you have a non-BES IBR?
- Registration: Your first required action is registering your category 2 IBR Facility(ies) with NERC by May 2026. Utility Services is here to help you with the registration process itself and can communicate on your behalf with NERC and the applicable Regional Entity to ensure this is as seamless as possible.
- Program Build for Category 2 enforceable standards: Your next action will be to prepare for and develop your compliance program to meet the applicable NERC Standards. Initially, this will require developing your program documentation for the identified eight Standards that will become immediately applicable to Category 2 IBRs in May 2026, and the newly approved standards PRC-028-1, PRC-029-1 and PRC-030-1. Utility Services is here to help you build your overall program customized to your system configuration, staffing, and compliance resources, to ensure you are following the requirements of all applicable standards.
- Monitor Standards development and prepare: NERC will continue the process of revising and possibly creating reliability standards that will be applicable for Category 2 IBRs. Utility Services is actively monitoring these developments and identifying the compliance requirements and enforceable dates of these new standards. As part of the program build support, we will provide you with periodic updates and information associated with future enforceable dates. Once the enforcement dates of each Standard become known, we will work with you to begin building the program(s) to meet and maintain compliance.
- Continued development and maintenance of the compliance programs: Once registered and your compliance programs are established to meet NERC approved standards, you will need to apply and utilize these documented programs to maintain compliance with the applicable Requirements going forward. As the Requirements are developed using results-based principles focused on measurable performance, risk mitigation strategies, and entity capabilities, many have required continual follow-up actions based on a triggering event or time intervals, such as relay testing that will be required every six years, and changes to your facilities. Utility Services can assist you in maintaining a long-lasting successful compliance program, as well as through its Routine Services maintenance program offerings designed to provide continuous oversight, guidance, and support in meeting the ever changing industry landscape.
Please see the NERC Compliance Program Development and Maintenance services page to understand more about how Utility Services can build and help maintain your program. Please contact us if you have any questions.
