NERC Advances Inverter-Based Resource Registration With FERC Petition

The North American Electric Reliability Corporation ("NERC") has taken an important step in implementing revised reliability standards for inverter-based resources ("IBRs"). In an August 27, 2025 petition filed with FERC ("NERC Petition"), NERC requested expedited approval of NERC Glossary[1] terms "Generator Owner" ("GO") and "Generator Operator" ("GOP") to include certain IBRs that are not directly connected to the Bulk Electric System ("BES").[2]

NERC proposed these revised definitions of GO and GOP to align these definitions with recently revised GO and GOP registration functions and criteria in the NERC Rules of Procedure that were approved by FERC on June 27, 2024.[3] Under the revised registry criteria, owners and operators of non-BES inverter-based resources ("IBRs") that individually or collectively have an aggregate nameplate capacity of greater than or equal to 20 MVA, 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, will meet the "Category 2" criteria and be required to register with NERC as a GO or GOP, as applicable.[4]

Together, the revised registry criteria, definitions, and NERC's implementation plan would ensure that owners and operators of IBRs on the BEW that are below the BES threshold but still have a material impact on BES reliability will be required to register and comply with applicable NERC reliability standards by May 15, 2026, thereby enhancing reliability of the BES by "addressing the growing impacts associated with the transforming resource mix and increasing integration of IBRs."[5]

By adding Category 2 criteria to the definition of GO and GOP in the NERC Glossary, NERC noted that the following eight reliability standards could become applicable to entities registering under the Category 2 criteria without any further revision to the standards:

• BAL-001 TRE (Primary Frequency Response in the ERCOT Region)
• IRO-010-5 (Reliability Coordinator Data and Information Specification and Collection)
• MOD-032-1 (Data for Power System Modeling and Analysis)
• PRC-012 (Remedial Action Schemes)
• PRC-017-1 (Remedial Action Scheme Maintenance and Testing)
• TOP-003-6.1 (Transmission Operator and Balancing Authority Data and Information Specification and Collection)
• VAR-001-5 (Voltage and Reactive Control)
• VAR-002-4.1 (Generator Operation for Maintaining Network Voltage Schedules)

These standards help ensure the reliable operation of the BES by requiring data sharing to increase situational awareness and by requiring equipment protection to safeguard generating resources.[6]

The import of the filing of the NERC Petition, if approved by FERC in an expedited manner, will be that a number of additional NERC reliability standards as noted above will become applicable to certain IBR owners and operators by May 15, 2026. Entities that own and/or operate eligible IBRs should be mindful of this implementation schedule and begin preparations now to ascertain whether they should register their IBR facilities and, if so, to plan for timely compliance with applicable NERC reliability standards.

If you have any questions, please contact the authors of this advisory.

*Daimen Flores, energy paralegal, also contributed to this article.