# Reliability Standards To Address Inverter-Based Resources > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/fr%3A2023-23581 ## Record - **Collection:** Federal Register - **Document type:** Rule - **Published:** October 30, 2023 - **Citation:** 88 FR 74250 ## Text DEPARTMENT OF ENERGY Federal Energy Regulatory Commission 18 CFR Part 40 [Docket No. RM22-12-000; Order No. 901] Reliability Standards To Address Inverter-Based Resources AGENCY: Federal Energy Regulatory Commission, Department of Energy. ACTION: Final action. SUMMARY: The Federal Energy Regulatory Commission (Commission) is directing the North American Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability Organization, to develop new or modified Reliability Standards that address reliability gaps related to inverter-based resources in the following areas: data sharing; model validation; planning and operational studies; and performance requirements. The Commission is also directing NERC to submit to the Commission an informational filing within 90 days of the issuance of this final action that includes a detailed, comprehensive standards development plan providing that all new or modified Reliability Standards necessary to address the inverter-based resource-related reliability gaps identified in this final action be submitted to the Commission by November 4, 2026. DATES: This rule is effective December 29, 2023. FOR FURTHER INFORMATION CONTACT: Eugene Blick (Technical Information), Office of Electric Reliability, Federal Energy Regulatory Commission, 888 First Street NE, Washington, DC 20426, (202) 502-8803, Eugene.Blick@ferc.gov . Felicia West (Legal Information), Office of the General Counsel, Federal Energy Regulatory Commission, 888 First Street NE, Washington, DC 20426, (202) 502-8948, Felicia.West@ferc.gov . SUPPLEMENTARY INFORMATION: Table of Contents Paragraph Nos. I. Information 1 II. Background 9 A. Section 215 of the FPA and the Mandatory Reliability Standards 9 B. Inverter-Based Resources 11 C. Notice of Proposed Rulemaking 16 III. Need for Reform 24 A. Current Actions Are Insufficient To Address IBR Reliability Risks 26 B. Existing Reliability Standards Do Not Adequately Address IBR Reliability Risks 37 1. Data Sharing 37 2. Data and Model Validation 42 3. Planning and Operational Studies 49 4. Performance Requirements 50 IV. Discussion 53 A. Commission Authority To Direct the ERO To Develop New or Modified Reliability Standards Under Section 215 of the FPA 59 1. Comments 60 2. Commission Determination 63 B. Data Sharing 66 1. Registered IBR Data Sharing 68 2. Disturbance Monitoring Data Sharing 81 3. Unregistered IBR and IBR-DER Data Sharing 87 C. Data and Model Validation 110 1. Approved Component Models 112 2. Verification of IBR Plant Dynamic Model Performance 128 3. Validating and Updating System Models 151 4. Need for Coordination When Creating and Updating Planning, Operational, and Interconnection-Wide Data and Models 158 D. Planning and Operational Studies 162 1. Comments 167 2. Commission Determination 174 E. Performance Requirements 178 1. Registered IBR Frequency and Voltage Ride Through Requirements 178 2. Bulk-Power System Planners and Operators Voltage Ride Through Mitigation Activities 196 3. Post-Disturbance IBR Ramp Rate Interactions and Phase Lock Loop Synchronization 200 F. Informational Filing and Reliability Standard Development Timeline 212 1. Comments 214 2. Commission Determination 222 V. Information Collection Statement 231 VI. Environmental Analysis 234 VII. Regulatory Flexibility Act 235 VIII. Document Availability 237 IX. Effective Date and Congressional Notification 240 Appendix A: Commenter Names Appendix B: NERC IBR Resources Cited in the Final Action I. Introduction 1. Pursuant to section 215(d)(5) of the Federal Power Act (FPA), 1 the Federal Energy Regulatory Commission (Commission) directs the North American Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability Organization (ERO), to submit new or modified Reliability Standards 2 that address specific matters pertaining to the impacts of inverter-based resources (IBR) 3 on the reliable operation 4 of the Bulk-Power System. 5 As proposed in the notice of proposed rulemaking (NOPR), we direct NERC to develop new or modified Reliability Standards addressing reliability gaps pertaining to IBRs in four areas: (1) data sharing; (2) model validation; (3) planning and operational studies; and (4) performance requirements. 6 NERC may propose to develop new or modified Reliability Standards that address our concerns in an equally efficient and effective manner; however, NERC's proposal should explain how the new or modified Reliability Standards address the Commission's concerns discussed in this final action. 7 1 16 U.S.C. 824o(d)(5) (the Commission may order the Electric Reliability Organization (ERO) to submit to the Commission a proposed Reliability Standard or a modification to a Reliability Standard that addresses a specific matter if the Commission considers such a new or modified Reliability Standard appropriate to carry out FPA section 215). 2 The FPA defines Reliability Standard as requirements for the operation of existing Bulk-Power System facilities, including cybersecurity protection, and the design of planned additions or modifications to such facilities to the extent necessary to provide for reliable operation of the Bulk-Power System, but the term does not include any requirement to enlarge such facilities or to construct new transmission capacity or generation capacity. Id. 824o(a)(3); see also 18 CFR 39.1. 3 This final action uses the term IBR generally to include all generation resources that connect to the electric power system using power electronic devices that change direct current (DC) power produced by a resource to alternating current (AC) power compatible with distribution and transmission grids. IBRs may refer to solar photovoltaic (PV), wind, fuel cell, and battery storage resources. 4 The FPA defines reliable operation as operating the elements of the Bulk-Power System within equipment and electric system thermal, voltage, and stability limits so that instability, uncontrolled separation, or cascading failures of such system will not occur as a result of a sudden disturbance, including a cybersecurity incident, or unanticipated failure of system elements. 16 U.S.C. 824o(a)(4); see also 18 CFR 39.1. 5 The Bulk-Power System is defined in the FPA as facilities and control systems necessary for operating an interconnected electric energy transmission network (or any portion thereof), and electric energy from generating facilities needed to maintain transmission system reliability. The term does not include facilities used in the local distribution of electric energy. 16 U.S.C. 824o(a)(1); see also 18 CFR 39.1. 6 Reliability Standards to Address Inverter-based Res., Notice of Proposed Rulemaking, 87 FR 74541 (Dec. 6, 2022), 181 FERC ¶ 61,125, at P 1 (2022) (NOPR). 7 See, e.g., Mandatory Reliability Standards for the Bulk-Power Sys., Order No. 693, 72 FR 16416 (Apr. 4, 2007), 118 FERC ¶ 61,218, at PP 186, 297, order on reh'g, Order No. 693-A, 72 FR 40717 (July 25, 2007), 120 FERC ¶ 61,053 (2007) (“[W]here the Final Rule identifies a concern and offers a specific approach to address the concern, we will consider an equivalent alternative approach provided that the ERO demonstrates that the alternative will address the Commission's underlying concern or goal as efficiently and effectively as the Commission's proposal.”). 2. We take this action in light of the rapid change in the mix of generation resources 8 connecting to the Bulk-Power System, including the addition of an “unprecedented proportion of nonsynchronous resources” 9 projected to connect over the next decade, including many generation resources that employ inverters, rectifiers, and converters 10 to provide energy to the Bulk-Power System. According to NERC, the rapid integration of IBRs is “the most significant driver of grid transformation” on the Bulk-Power System. 11 8 The Reliability Standards use both terms “generation resources” and “generation facilities” to define sources of electric power on the transmission system. This final action uses the term “generation resources.” 9 NERC, 2020 Long Term Reliability Assessment Report, 9 (Dec. 2020), https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_LTRA_2020.pdf (2020 LTRA Report). 10 An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is a power electronic device that rectifies AC sinusoidal power to DC power. A converter is a power electronic device that performs rectification and/or inversion. Consistent with NERC's terminology, this order uses the term “inverter” to refer to generating facilities that use power electronic inversion, rectification, and conversion. NERC, Inverter-Based Resource Performance and Analysis Technical Workshop, 29 (Feb. 2019), https://www.nerc.com/comm/PC/IRPTF%20Workshops/IRPTF_Workshop_Presentations.pdf . 11 NERC, Inverter-Based Resource Strategy: Ensuring Reliability of the Bulk Power System with Increased Levels of BPS-Connected IBRs, 1 (June 2022), https://www.nerc.com/comm/Documents/NERC_IBR_Strategy.pdf (NERC IBR Strategy). 3. The Reliability Standards, first approved by the Commission in 2007, were developed to apply to the types of generation resources prevalent at that time—nearly exclusively synchronous generation resources—to ensure the reliable operation of the Bulk-Power System. As a result, the Reliability Standards may not account for the material technological differences between the response of synchronous generation resources and the response of IBRs to the same disturbances on the Bulk-Power System. 12 12 See, e.g., NERC, 2013 Long-Term Reliability Assessment, 22 (Dec. 2013), https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/2013_LTRA_FINAL.pdf (2013 LTRA Report) (finding that reliably integrating high levels of variable resources into the Bulk-Power System would require “significant changes to traditional methods used for system planning and operation,” including requiring “new tools and practices, including potential enhancements to . . . Reliability Standards or guidelines to maintain [Bulk-Power System] reliability.”). 4. We also take this action because, as discussed in more detail in section III below, we find that the currently effective Reliability Standards do not ensure that Bulk-Power System planners and operators 13 have the necessary tools to plan for and reliably integrate IBRs into the Bulk-Power System or to plan for IBRs connected to the distribution system that in the aggregate have a material impact on the Bulk-Power System (IBR-DER). IBRs, individually and in the aggregate, and IBR-DERs in the aggregate can have a material impact on the reliable operation of the Bulk-Power System. 14 Additionally, the Reliability Standards do not contain performance requirements that are unique to IBRs and are necessary to ensure that IBRs operate in a predictable and reliable manner. 13 Bulk-Power System planners and operators include planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities, and any other functional entity NERC may identify as applicable to meet the directives in this final action. 14 NERC reports do not always differentiate between IBRs based on type, or between those subject to Reliability Standards and those located on the distribution system. Where necessary to describe our directives, however, we differentiate between IBRs registered with NERC (or which will be registered pursuant to the Commission's directives in Registration of Inverter-based Resources, 181 FERC ¶ 61,124 (2022) (IBR Registration Order)) and therefore subject to the Reliability Standards ( i.e., registered IBR), IBRs connected directly to the Bulk-Power System but not registered with NERC and therefore not subject to the Reliability Standards ( i.e., unregistered IBRs), and IBRs connected to the distribution system that in the aggregate have a material impact on the Bulk-Power System ( i.e., IBR-DER). Although the remaining subset of unregistered IBRs and IBR-DERs in the aggregate will not be subject to the mandatory and enforceable Reliability Standards set forth herein, they may be subject to provision of data and information to their respective transmission owners and distribution providers, as applicable, in accordance with their specific interconnection agreements. We encourage NERC to continue its efforts to review and evaluate whether reliability gaps continue to remain and if new or modified functional registration categories or Reliability Standards are necessary. See infra note 365 (discussing NERC's estimate of the percentage of IBRs to be registered under its registration work plan). 5. As discussed in greater detail below, we therefore direct NERC, pursuant to section 215(d)(5) of the FPA and § 39.5(f) of the Commission's regulations, to develop new or modified Reliability Standards that address the following specific issues: • IBR Data Sharing: The Reliability Standards must require that generator owners, transmission owners, and distribution providers share validated modeling, planning, operations, and disturbance monitoring data for all IBRs with planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities so that the latter group has the necessary data to predict the behavior of registered and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate, and their impact on the reliable operation of the Bulk-Power System. • IBR Model Validation: The Reliability Standards must require that all IBR models are comprehensive, validated, and updated in a timely manner, so that planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities can adequately predict the behavior of registered and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate, and their impacts on the reliable operation of the Bulk-Power System. • IBR Planning and Operational Studies: The Reliability Standards must require that planning and operational studies include validated IBR models to assess the reliability impacts of registered and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate, on the reliable operation of the Bulk-Power System. The Reliability Standards must require that planning and operational studies assess the impacts of all IBRs within and across planning and operational boundaries for normal operations and contingency event conditions. • IBR Performance Requirements: The Reliability Standards must ensure that registered IBRs will provide frequency and voltage support during frequency and voltage excursions in a manner necessary to contribute toward the overall system needs for essential reliability services. 15 The Reliability Standards must establish clear and reliable technical limits and capabilities for registered IBRs to ensure that all registered IBRs are operated in a predictable and reliable manner during normal operations and contingency event conditions. The Reliability Standards must require that the operational aspects of registered IBRs contribute towards meeting the overall system needs for essential reliability services. The Reliability Standards must include post-disturbance ramp rates and phase lock loop synchronization requirements for registered IBRs. 15 See, e.g., NERC, A Concept Paper on Essential Reliability Services that Characterizes Bulk Power System Reliability, vi (Oct. 2014), https://www.nerc.com/comm/Other/essntlrlbltysrvcstskfrcDL/ERSTF%20Concept%20Paper.pdf (Essential Reliability Services Concept Paper) (listing the essential reliability services necessary to maintain Bulk-Power System reliability). 6. Pursuant to § 39.2(d) of the Commission's regulations, 16 we direct NERC to submit an informational filing within 90 days of the issuance of the final action in this proceeding. NERC's filing shall include a detailed and comprehensive standards development plan explaining how NERC will prioritize the development of new or modified Reliability Standards to meet the deadlines set forth in this final action. We direct NERC to explain in its filing how it is prioritizing its IBR Reliability Standard projects to meet the directives in this final action, taking into account the risk posed to the reliability of the Bulk-Power System, standard development projects already underway, resource constraints, and other factors if necessary. 16 18 CFR 39.2(d) (the electric reliability organization shall provide the Commission information as necessary to implement section 215 of the FPA). 7. NERC's standards development plan must ensure that NERC submits new or modified Reliability Standards by the following deadlines. First, by November 4, 2024, NERC must submit new or modified Reliability Standards that establish IBR performance requirements, including requirements addressing frequency and voltage ride through, 17 post-disturbance ramp rates, phase lock loop synchronization, and other known causes of IBR tripping or momentary cessation. 18 NERC must also submit, by November 4, 2024, new or modified Reliability Standards that require disturbance monitoring data sharing and post-event performance validation for registered IBRs. Second, by November 4, 2025, NERC must submit new or modified Reliability Standards addressing the interrelated directives concerning: (1) data sharing for registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate; and (2) data and model validation for registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate. Finally, by November 4, 2026, NERC must submit new or modified Reliability Standards addressing planning and operational studies for registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate. We continue to believe this staggered approach to standard development and implementation is necessary based on the scope of work anticipated and that specific target dates will provide a valuable tool and incentive to NERC to timely address the directives in this final action. 17 See Standardization of Generator Interconnection Agreements & Procs., Order No. 2003, 104 FERC ¶ 61,103, at P 562 n.88 (2003) (defining ride through as “a Generating Facility staying connected to and synchronized with the Transmission System during system disturbances within a range of over- and under-frequency[/voltage] conditions, in accordance with Good Utility Practice.”). 18 Momentary cessation is a mode of operation during which the inverter remains electrically connected to the Bulk-Power System, but the inverter does not inject current during low or high voltage conditions outside the continuous operating range. As a result, there is no current injection from the inverter and therefore no active or reactive current (and no active or reactive power). NERC, Reliability Guideline: BPS-Connected Inverter-Based Resource Performance, 11 (Sept. 2018), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/Inverter-Based_Resource_Performance_Guideline.pdf (IBR Performance Guideline). 8. Although we are not directing NERC to include implementation dates in its informational filing and are leaving determination of the appropriate effective dates to the standards development process, we are concerned that the lack of a time limit for implementation could allow identified issues to remain unresolved for a significant and indefinite period. Therefore, we emphasize that industry has been aware of and alerted to the need to address the impacts of IBRs on the Bulk-Power System since at least 2016. The number of events, NERC Alerts, reports, whitepapers, guidelines, and ongoing standards projects, as discussed in more detail in section III and throughout this final action, more than demonstrate the need for the expeditious implementation of new or modified Reliability Standards addressing IBR data sharing, data and model validation, planning and operational studies, and performance requirements. Thus, in that light, the Commission will take these issues into account when it considers the proposed implementation plan for each new or modified Reliability Standard when it is submitted for Commission. Further, as a general matter, we believe that there is a need to have all the directed Reliability Standards effective and enforceable well in advance of 2030 and direct NERC to ensure that the associated implementation plans sequentially stagger the effective and enforceable dates to ensure an orderly industry transition for complying with the IBR directives in this final action prior to 2030. II. Background A. Section 215 of the FPA and the Mandatory Reliability Standards 9. Section 215 of the FPA provides that the Commission may certify an ERO, the purpose of which is to develop mandatory and enforceable Reliability Standards, subject to Commission review and approval. 19 Reliability Standards may be enforced by the ERO, subject to Commission oversight, or by the Commission independently. 20 Pursuant to section 215 of the FPA, the Commission established a process to select and certify an ERO, 21 and subsequently certified NERC. 22 19 16 U.S.C. 824o(c). 20 Id. 824o(e). 21 Rules Concerning Certification of the Elec. Reliability Org. & Procs. for the Establishment, Approval, & Enf't. of Elec. Reliability Standards, Order No. 672, 114 FERC ¶ 61,104, order on reh'g, Order No. 672-A, 114 FERC ¶ 61,328 (2006). 22 N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062, order on reh'g and compliance, 117 FERC ¶ 61,126 (2006), aff'd sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009). 10. Pursuant to section 215(d)(5) of the FPA, the Commission has the authority, upon its own motion or upon complaint, to order the ERO to submit to the Commission a proposed Reliability Standard or a modification to a Reliability Standard that addresses a specific matter if the Commission considers such a new or modified Reliability Standard appropriate to carry out section 215 of the FPA. 23 Further, pursuant to § 39.5(g) of the Commission's regulations, the Commission may order a deadline by which the ERO must submit a proposed or modified Reliability Standard. 24 23 16 U.S.C. 824o(d)(5). 24 18 CFR 39.5(g). B. Inverter-Based Resources 11. The Bulk-Power System generation fleet has traditionally been composed almost exclusively of synchronous generation resources that convert mechanical energy into electric energy through electromagnetic induction. By virtue of the kinetic energy in their large rotating components, these synchronous generation resources inherently resist changes in system frequency, providing time for other governor controls (when properly configured) to maintain supply and load balance. Similarly, synchronous generation resources inherently provide voltage support during voltage disturbances. 12. In contrast, IBRs do not use electromagnetic induction from machinery that is directly synchronized to the Bulk-Power System. Instead, the majority of installed IBRs use grid-following inverters, which rely on sensed information from the grid ( e.g., a voltage waveform) to produce the desired AC real and reactive power output. 25 Due to their inverters, IBRs can track grid state parameters ( e.g., voltage angle) in milliseconds and react nearly instantaneously to changing grid conditions. Some IBRs, however, are not configured or programmed to support grid voltage and frequency in the event of a system disturbance, and, as a result, will reduce power output, 26 exhibit momentary cessation, or trip in response to variations in system voltage or frequency. 27 In other words, under certain conditions some IBRs cease to provide power to the Bulk-Power System due to how they are configured and programmed. Nonetheless, some models and simulations incorrectly predict that some IBRs will ride through disturbances, i.e., maintain real power output at pre-disturbance levels and provide voltage and frequency support consistent with Reliability Standard PRC-024-3 (Frequency and Voltage Protection Settings for Generating Resources). 28 25 See, e.g., NERC, 2021 Long Term Reliability Assessment Report, 6 (Dec. 2021), https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_LTRA_2021.pdf (2021 LTRA Report) (“IBRs respond to disturbances and dynamic conditions based on programmed logic and inverter controls, not mechanical characteristics.”); see also generally, Denholm et al., National Renewable Energy Laboratory, Inertia and the Power Grid: A Guide Without the Spin, NREL/TP-6120-73856, v (May 2020), https://www.nrel.gov/docs/fy20osti/73856.pdf . 26 NERC and WECC, San Fernando Disturbance, 2 (Nov. 2020), https://www.nerc.com/pa/rrm/ea/Documents/San_Fernando_Disturbance_Report.pdf (San Fernando Disturbance Report) (covering the San Fernando event (July 7, 2020)). 27 See Essential Reliability Servs. & the Evolving Bulk-Power Sys. Primary Frequency Response, Order No. 842, 162 FERC ¶ 61,128, at P 19 (2018) (describing NERC's comment that increased IBR deployment alongside retirement of synchronous generation resources has contributed to the decline in primary frequency response); see also NERC, Fast Frequency Response Concepts and Bulk Power System Reliability Needs, 5 (Mar. 2020), https://www.nerc.com/comm/PC/InverterBased%20Resource%20Performance%20Task%20Force%20IRPT/Fast_Frequency_Response_Concepts_and_BPS_Reliability_Needs_White_Paper.pdf (Fast Frequency Response White Paper) (explaining that as the instantaneous penetration of IBRs with little or no inertia continues to increase, system rate of change of frequency after a loss of generation will increase and the time available to deliver frequency responsive reserves will shorten, and illustrating the steeper rate of change of frequency and the importance of speed of response). 28 The NOPR referred to Reliability Standard PRC-024-2; however, Reliability Standard PRC-024-3 became mandatory and enforceable on October 1, 2022. Reliability Standards applicable in the United States, both effective and retired, are available at https://www.nerc.com/pa/Stand/Pages/USRelStand.aspx . 13. IBRs across the Bulk-Power System exhibit common mode failures that are amplified when IBRs act in the aggregate. 29 Thus, both localized and interconnection-wide IBR issues must be identified, studied, and mitigated to preserve Bulk-Power System reliability. 30 Although IBRs are typically smaller-megawatt (MW) facilities, they are at greater risk than synchronous generation resources of ceasing to provide power to the Bulk-Power System in response to a single fault on the transmission or sub-transmission systems. Specifically, such response can occur when individual IBR controls and equipment protection settings are not configured to ride through system disturbances. 31 IBRs that enter momentary cessation may act in aggregate and cause a reduction in power output far in excess of any individual IBR's impact on the Bulk-Power System. The potential impact of IBRs is not restricted by the size of a single facility or an individual balancing authority area, but by the number of IBRs or percent of generation made up by IBRs within a region. In areas of high IBR penetration, this type of aggregate response may have an impact much greater than the most severe single contingency ( i.e., the traditional worst-case N-1 contingency) 32 of a balancing authority area, potentially adversely affecting other balancing authority areas within an interconnection. 33 Unless IBRs are configured and programmed to ride through normally cleared transmission faults, the potential impact of losing IBRs individually or in the aggregate will continue to increase as IBRs are added to the Bulk-Power System and make up an increasing proportion of the resource mix. 29 NERC, An Introduction to Inverter-Based Resources on the Bulk-Power System, 6 (June 2023), https://www.nerc.com/pa/Documents/2023_NERC_Guide_Inverter-Based-Resources.pdf (explaining that “NERC continues to analyze large-scale grid disturbances involving common mode failures in inverter-based resources that, if not addressed, could lead to catastrophic events in the future”). 30 See NOPR, 181 FERC ¶ 61,125 at P 4. 31 See, e.g., NERC and WECC, 900 MW Fault Induced Solar Photovoltaic Resource Interruption Disturbance Report, 19 (Feb. 2018), https://www.nerc.com/pa/rrm/ea/October%209%202017%20Canyon%202%20Fire%20Disturbance%20Report/900%20MW%20Solar%20Photovoltaic%20Resource%20Interruption%20Disturbance%20Report.pdf (Canyon 2 Fire Event Report) (covering the Canyon 2 Fire event (October 9, 2017)) (finding momentary cessation as a major cause for the loss of IBRs when voltages rose above 1.1 per unit or decreased below 0.9 per unit). 32 The most severe single contingency, or the N-1 contingency, generally refers to the concept that a system must be able to withstand an unexpected failure or outage of a single system component and maintain reliable service at all times. See, e.g., NERC, Glossary of Terms Used in NERC Reliability Standards, 17 (Mar. 8, 2023), https://www.nerc.com/pa/Stand/Glossary%20of%20Terms/Glossary_of_Terms.pdf (NERC Glossary) (defining “most severe single contingency”). 33 See, e.g., San Fernando Disturbance Report at vi (stating that “[t]his event, as with past events, involved a significant number of solar PV resources reducing power output (either due to momentary cessation or inverter tripping) as a result of normally-cleared [Bulk-Power System] faults. The widespread nature of power reduction across many facilities poses risks to [Bulk-Power System] performance and reliability.”). 14. Simulations conducted by the NERC Resource Subcommittee demonstrate that the risks to Bulk-Power System reliability posed by momentary cessation are greater than any of the actual IBR disturbances that NERC has documented since 2016. 34 These simulations indicate the potential for: (1) normally-cleared, three-phase faults at certain locations in the Western Interconnection to result in upwards of 9,000 MW of solar PV IBRs entering momentary cessation across a large geographic region; (2) transient instability caused by excessive transfer of inter-area power flows during and after momentary cessation; and (3) a drop in frequency that falls below the first stage of under frequency load shedding in the Western Electricity Coordinating Council (WECC) region (traditionally studied as the loss of the two Palo Verde nuclear units in Arizona, which total approximately 2,600 MW). These simulation results indicate that IBR momentary cessation occurring in the aggregate can lead to instability, system-wide uncontrolled separation, and voltage collapse. 35 34 See NERC, Resource Loss Protection Criteria Assessment, (Feb. 2018), https://www.nerc.com/comm/PC/InverterBased%20Resource%20Performance%20Task%20Force%20IRPT/IRPTF_RLPC_Assessment.pdf . 35 Id. at 1-2, key findings 4, 7, 8. 15. Although IBRs present risks that Bulk-Power System planners and operators must account for, IBRs also present new opportunities to support the grid and respond to abnormal grid conditions. 36 When appropriately programmed, IBRs can operate during greater frequency deviations ( i.e., a wider frequency range) than synchronous generation resources. 37 This operational flexibility—and the ability of IBRs to perform with precision, speed, and control—could mitigate disturbances on the Bulk-Power System. For Bulk-Power System operators to harness the unique performance and control capabilities of IBRs, these resources must be properly configured and programmed to support grid voltage and frequency during normal and abnormal grid conditions and must be accurately modeled and represented in transmission planning and operations models. 36 See, e.g., IBR Performance Guideline at vii (finding that the power electronics aspects of IBRs “present new opportunities in terms of grid control and response to abnormal grid conditions.”). 37 See, e.g., Fast Frequency Response White Paper at 11. C. Notice of Proposed Rulemaking 16. On November 17, 2022, the Commission issued the NOPR in this proceeding, proposing to direct NERC to submit new or modified Reliability Standards addressing four gaps in the currently effective Reliability Standards pertaining to IBRs: (1) data sharing; (2) model validation; (3) planning and operational studies; and (4) performance requirements. 38 The Commission initiated this action in light of the rapid change in the generation resource mix currently underway on the Bulk-Power System and the projected addition of unprecedented numbers of IBRs to the Bulk-Power System. 39 The Commission noted that IBRs provide many benefits, but that IBRs also present new considerations for transmission planning and operation of the Bulk-Power System. 40 38 NOPR, 181 FERC ¶ 61,125 at P 1. 39 Id. P 2 (citing 2020 LTRA Report). 40 Id. 17. The Commission proposed to direct NERC to address the four reliability gaps by developing one or more new Reliability Standards or modifying the currently effective Reliability Standards. The Commission did not propose specific requirements; instead, the Commission identified concerns that the Reliability Standards should address. The Commission sought comments on its identified concerns and whether there were other concerns related to planning for and integrating IBRs that the Commission should direct NERC to address in this or a future proceeding. 41 41 Id. P 6. 18. First, the Commission proposed to direct NERC to develop new or modified Reliability Standards addressing IBR data sharing. The Commission proposed that the new or modified Reliability Standards should ensure that NERC registered entities 42 have the necessary data to predict the behavior of all IBRs, including registered and unregistered IBRs individually and in the aggregate, and IBR-DERs in the aggregate, and their impact on the reliable operation of the Bulk-Power System. The Commission stated that the new or modified Reliability Standards should ensure that generator owners, transmission owners, and distribution providers are required to share validated modeling, planning, operations, and disturbance monitoring data for registered and unregistered IBRs and IBR-DERs in the aggregate with planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities. 43 42 NERC identifies and registers Bulk-Power System users, owners, and operators who are responsible for performing specified reliability functions to which requirements of mandatory Reliability Standards are applicable. See NERC, Rules of Procedure, Section 500 (Organization Registration and Certification) (Aug. 25, 2022), https://www.nerc.com/AboutNERC/RulesOfProcedure/NERC%20ROP%20effective%2020220825_with%20appendicies.pdf . 43 NOPR, 181 FERC ¶ 61,125 at P 5. 19. Second, the Commission proposed to direct NERC to develop new or modified Reliability Standards addressing IBR model validation. The Commission proposed that the new or modified Reliability Standards should ensure that IBR models are comprehensive, validated, and updated in a timely manner, so that they can adequately predict the behavior of registered and unregistered IBRs individually and in the aggregate, and IBR-DERs in the aggregate, and their impacts on the reliable operation of the Bulk-Power System. 44 44 Id. 20. Third, the Commission proposed to direct NERC to develop new or modified Reliability Standards addressing IBR planning and operational studies. The Commission proposed to direct that the new or modified Reliability Standards ensure that validated IBR models are included in transmission planning and operational studies to assess the reliability impacts on Bulk-Power System performance by registered and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate. The Commission stated that the Reliability Standards should ensure that planning and operational studies assess the impacts of registered and unregistered IBRs individually and in the aggregate, and IBR-DERs in the aggregate, within and across planning and operational boundaries for normal operations and contingency event conditions. 45 45 Id. 21. Fourth, the Commission proposed to direct NERC to develop new or modified Reliability Standards addressing IBR performance requirements. 46 The Commission explained that the new or modified Reliability Standards should require that registered IBRs provide frequency and voltage support during frequency and voltage excursions, including post-disturbance ramp rates and phase lock loop synchronization, in a manner necessary to contribute toward meeting the overall system needs for essential reliability services. 47 Further, the Commission stated that the new or modified Reliability Standards should establish clear and reliable technical limits and capabilities for registered IBRs to ensure that all registered IBRs are operated in a predictable and reliable manner during both normal operations and contingency event conditions. 46 Id. 47 Id. (citing Essential Reliability Services Concept Paper at vi). 22. Finally, the Commission proposed to direct NERC to submit a compliance filing within 90 days of the effective date of the final action in this proceeding. The Commission proposed to direct NERC to include in its compliance filing a detailed, comprehensive standards development and implementation plan explaining how NERC will prioritize the development and implementation of new or modified Reliability Standards. The Commission stated that NERC should explain how it would prioritize its IBR Reliability Standard projects to meet the directives in the final action, taking into account the risk posed to the reliability of the Bulk-Power System, standard development projects already underway, resource constraints, and other factors if necessary. 48 48 Id. P 7. 23. The comment period for the NOPR ended on February 6, 2023, with reply comments due on March 6, 2023. The Commission received 18 initial comments and 3 reply comments. 49 49 A list of commenters to the NOPR and the abbreviated names used in this final action appear in Appendix A. Interventions are not necessary to file comments in a rulemaking. Nevertheless, Acciona Energy USA Global LLC, Cordelio USA, Inc., Electricity Consumers Resource Council, the Federal Energy Advocate, the Public Utilities Commission of Ohio, Georgia Transmission Corporation, GlidePath Development, LLC, Monitoring Analytics, LLC, and Old Dominion Electric Cooperative filed motions to intervene. III. Need for Reform 24. As the Commission explained in the NOPR, a number of events have demonstrated the challenges to transmission planning and operations of the Bulk-Power System posed by gaps in the Reliability Standards specific to IBRs. 50 In this final action, we continue to find that as the resource mix trends towards higher penetrations of IBRs, the need to reliably integrate these resources into the Bulk-Power System is expected to grow, and that the currently effective Reliability Standards do not adequately address IBR reliability risks. 51 The continuing risks that the increasing penetration of IBRs pose to the reliable operation of the Bulk-Power System underscore the need for mandatory Reliability Standards to address these issues on a nationwide basis. 50 See NOPR, 181 FERC ¶ 61,125 at PP 24-26. 51 Id. PP 26-27. 25. NERC, groups such as the Institute of Electrical and Electronics Engineers (IEEE), and other entities have attempted to address IBR-related reliability concerns at the manufacturer, state, local, or individual entity level over the past several years. 52 While the various ongoing IBR-related projects are important efforts, the absence of a comprehensive plan to require that the increasing numbers of IBRs are reliably interconnected, planned for, and operated on the Bulk-Power System limits those individual projects' overall impact. Moreover, these individual efforts could lead to inconsistent results that fail to fully address the gaps identified herein, a concern that could be resolved by addressing all IBR issues through the Reliability Standards. Therefore, to help ensure that a broader range of reliability concerns related to the impacts of IBRs on the Bulk-Power System are addressed, that any necessary new requirements apply nationwide, and that any new rules are mandatory, we find that it is imperative for NERC to develop new or modified Reliability Standards as directed in this final action to address reliability concerns related to IBRs at all stages of interconnection, planning, and operations. However, we note that the directives to NERC in this final action are intended to complement other ongoing NERC and Commission actions to address the impacts of all IBRs on the Bulk-Power System, as well as existing voluntary efforts underway, and are not intended to supersede or interfere with these efforts. 52 For example, to address gaps in data and model validation and to facilitate sharing and combining of neighboring planning models, ISO New England (ISO-NE) has taken steps to retire obsolete and unapproved models within its own footprint. See ISO-NE, Generator Data Submittal Requirements—Planning, Topic Retiring Obsolete and NERC Non-Approved Models, 121-125 (Jan. 24, 2023), https://www.iso-ne.com/static-assets/documents/2023/01/20230124-gen-data-submittal-requirements-planning.pdf. A. Current Actions Are Insufficient To Address IBR Reliability Risks 26. As explained in the NOPR, at least 12 documented events on the Bulk-Power System 53 show IBRs acting unexpectedly and adversely in response to normally cleared transmission line faults on the Bulk-Power System, each highlighting one or more common mode failures of IBRs of various sizes and voltage connection levels. 54 53 The 12 events report an average of approximately 1,000 MW of IBRs entering into momentary cessation or tripping in the aggregate. The 12 Bulk-Power System events are: (1) the Blue Cut Fire (August 16, 2016); (2) the Canyon 2 Fire (October 9, 2017); (3) Angeles Forest (April 20, 2018); (4) Palmdale Roost (May 11, 2018); (5) San Fernando (July 7, 2020); (6) the first Odessa, Texas event (May 9, 2021); (7) the second Odessa, Texas event (June 26, 2021); (8) Victorville (June 24, 2021); (9) Tumbleweed (July 4, 2021); (10) Windhub (July 28, 2021); (11) Lytle Creek (August 26, 2021); and (12) Panhandle Wind Disturbance (March 22, 2022). 54 NOPR, 181 FERC ¶ 61,125 at P 4. 27. In addition to those 12 documented events discussed in the NOPR, on June 4, 2022, an IBR-related disturbance near Odessa, Texas (the third in this location) occurred. During this disturbance, a normally cleared single-line-to-ground fault resulted in a total loss of 2,555 MW of synchronous and IBR generation, and system frequency dropped to 59.7 Hz. 55 This is the largest (to date) NERC-recorded IBR-related disturbance event and the total loss of generation resources was one and half times larger than the average loss of the 12 preceding reported events. The NERC and Texas Reliability Entity, Inc. (Texas RE) joint report, issued in December 2022, explains that this event is significant because the size of this disturbance nearly exceeded the Texas Interconnection Resource Loss Protection Criteria ( i.e., 2,750 MW) defined in Reliability Standard BAL-003-2, 56 which is used to establish the largest credible contingency for frequency stability in an interconnection. 57 55 A power system deviating from 60 Hz indicates there is a generation and load imbalance. When the generation loss is too large, automatic under-frequency load shedding is used to rebalance the power system to prevent cascading failures that lead to blackouts. In Texas, the automatic under-frequency load shed (UFLS) program is set to trigger a sudden loss of load at 59.3 Hz. See generally Public Utility Commission of Texas, Load Shed Protocols for the Electric Reliability Council of Texas (ERCOT) Region, (Aug. 31, 2022), https://ftp.puc.texas.gov/public/puct-info/agency/resources/reports/leg/PUC_Load_Shed_Protocols_Study.pdf. See also NERC Newsroom Announcement Odessa Disturbance Illustrates Need for Immediate Industry Action on Inverter-Based Resources (Dec. 8, 2022), https://www.nerc.com/news/Headlines%20DL/OdessaDisturbance_08DEC22.pdf (explaining that “[t]he 2022 Odessa disturbance was a Category 3a event in the NERC Event Analysis Process, and the combined loss of generation nearly exceeded the Texas Interconnection Resource Loss Protection Criteria.”). 56 See Reliability Standard BAL-003-2 (Frequency Response and Frequency Bias Setting), attach. A. 57 NERC and Texas RE, 2022 Odessa Disturbance, v (Dec. 2022), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/NERC_2022_Odessa_Disturbance_Report%20(1).pdf (Odessa 2022 Disturbance Report) (covering events in Odessa, Texas on June 4, 2022). 28. In response to the multiple Odessa, Texas disturbances, NERC issued its third level 2 alert on IBR performance issues on March 14, 2023. 58 In the alert, NERC states its level 2 alert is necessary because the disturbances in Odessa, Texas, showed that solar PV IBR resources exhibited “systemic performance issues” with the potential to cause widespread outages on the Bulk-Power System. 59 Although the NERC alert pertains specifically to solar PV resources, the alert recommendations may be applicable to Bulk-Power System connected battery energy storage systems. Further, NERC explains that as the penetration of Bulk-Power System-connected IBRs increases, it will be necessary to address performance deficiencies in an “effective and efficient manner.” 60 In the March 2023 Alert, NERC sought to gather information from registered generator owners of solar-PV ( i.e., IBRs) and to encourage them to implement recommendations to: (1) ensure inverter protection settings, collector system settings, and substation settings are updated or changed to mitigate inadvertent operations; and (2) ensure that facility control modes, fault ride through modes and parameters, and protections are set and coordinated to facilitate Bulk-Power System voltage and frequency ride through. 61 58 NERC, Industry Recommendation: Inverter-Based Resource Performance Issues (Mar. 2023), https://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/NERC%20Alert%20R-2023-03-14-01%20Level%202%20-%20Inverter-Based%20Resource%20Performance%20Issues.pdf (March 2023 Alert). 59 See NOPR, 181 FERC ¶ 61,125 at P 18 (explaining that the level 2 alerts recommend specific voluntary action to be taken by registered IBRs). 60 March 2023 Alert at 1. 61 Id. 29. NERC also recently issued another disturbance report covering events in Southwest Utah in the morning of April 10, 2023. 62 NERC explains that the causes of the Southwest Utah disturbance are similar to past solar PV IBR-related events. 63 NERC identifies this event as the “first major widespread solar [PV] loss to occur in the Western Interconnection outside of California.” 64 62 NERC and WECC, 2023 Southwest Utah Disturbance (Aug. 2023), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/NERC_2023_Southwest_UT_Disturbance_Report.pdf (Southwest Utah Disturbance Report). 63 Id. at iv. 64 Id. 30. NERC has found that distributed energy resources' ( i.e., IBR-DERs') responses to Bulk-Power-System disturbances can cause short term net load increases likely attributed to aggregate IBR-DERs tripping. 65 This behavior and the resulting net load increases can impact Bulk-Power-System performance. 66 65 Multiple Solar PV Disturbances in CAISO: Disturbances between June and August 2021 Joint NERC and WECC Staff Report, 17-18, (Apr. 2022), https://www.nerc.com/pa/rrm/ea/Documents/NERC_2021_California_Solar_PV_Disturbances_Report.pdf. 66 San Fernando Disturbance: Southern California Event: July 7, 2020 Joint NERC and WECC Staff Report, 12 (Nov. 2020), https://www.nerc.com/pa/rrm/ea/Documents/San_Fernando_Disturbance_Report.pdf. 31. NERC has also issued two recent IBR-related Reliability Guidelines. In February 2023 NERC issued an updated guideline on aggregate DER modeling (DER_A model), 67 and in March 2023, NERC issued its first guideline on electromagnetic transient (EMT) modeling and studies for IBRs. 68 67 NERC, Reliability Guideline: Parameterization of the DER_A Model for Aggregate DER (Feb. 2023), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/Reliability_Guideline_ModelingMerge_Responses_clean.pdf (2023 DER_A Model Guideline). The DER_A model is the approved steady state and dynamic model that industry has validated and maintained to model IBR-DERs in the aggregate and used to study the potential impacts of IBR-DERs in the aggregate on the Bulk-Power System. The term “parameterize” means to adjust the parameter values of a generic model to best reflect the dynamic characteristics of a user-defined model. The parameterization process aims at reducing the difference (error) between the dynamic responses of both the generic and user-defined models. See, e.g., Energy Systems Integration Group, Parameterization, https://www.esig.energy/wiki-main-page/parameterization-d1/. 68 NERC, Reliability Guideline: Electromagnetic Transient Modeling for BPS-Connected Inverter-Based Resources—Recommended Model Requirements and Verification Practices (Mar. 2023), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/Reliability_Guideline-EMT_Modeling_and_Simulations.pdf (EMT Modeling Guideline). 32. NERC also has nine separate projects underway to update its currently effective Reliability Standards relevant to IBRs; however, these projects are still in their early stages and, even if they are completed, the results of these efforts may not fully address the reliability risks that IBRs pose to the Bulk-Power System described above. 69 69 The current NERC standards development projects underway include: (1) Project 2021-04 (Modifications to PRC-002-2) to ensure that disturbance monitoring data is available and provided by generator owners of IBR facilities; (2) Project 2020-06 (Verifications of Models and Data for Generators) to enhance requirements for model verification; (3) Project 2022-04 (EMT Modeling) to address the inclusion of EMT modeling and studies in relevant Reliability Standards; (4) Project 2022-02 (Modifications to TPL-001-5.1 and MOD-032-1) addressing certain issues regarding appropriate inclusion of IBRs and DERs in planning assessments; (5) Project 2020-02 (Modifications to PRC-024 (Generator Ride-through)) to revise or replace current Reliability Standard PRC-024-3 with a standard that will require ride through performance from all generation resources; (6) Project 2023-02 (Performance of IBRs) to address post-event performance validation ensuring that resources perform the way they are expected or required to perform; (7) Project 2021-01 (Modifications to MOD-025 and PRC-019) to ensure that plant active and reactive power capabilities are accurately provided to planning entities for use in studies; (8) Project 2021-02 (Modifications to VAR-002-4.1) to clarify whether the generator operator of a dispersed power resource must notify its associated transmission operator upon a status change of a voltage controlling device on an individual generating unit; and (9) Project 2023-01 (EOP-004 IBR Event Reporting) to ensure timely reporting of events involving IBRs. See NERC, Reliability Standards Under Development, https://www.nerc.com/pa/Stand/Pages/Standards-Under-Development.aspx. 33. While we recognize NERC's ongoing efforts, systemic fault ride through deficiencies continue to result in IBRs displaying unexpected and abnormal performance during grid disturbances. 70 In fact, in the March 2023 Alert, NERC states that IBR-related issues continue to occur and has announced plans to issue an alert by the end of 2023 regarding IBR modeling issues. 71 70 March 2023 Alert at 6-7. 71 Id. at 6. 34. The Commission has also been actively addressing ongoing IBR-related concerns. Concurrently with the NOPR, the Commission issued an order directing NERC to identify and register owners and operators of unregistered IBRs that in the aggregate have a material impact on the reliable operation of the Bulk-Power System. 72 On February 15, 2023, as amended on March 13, 2023, NERC submitted its compliance filing, which included its work plan setting out NERC's planned activities and milestones to register generator owners and operators of IBRs. On May 18, 2023, the Commission approved NERC's work plan and associated implementation milestones. 73 72 See IBR Registration Order, 181 FERC ¶ 61,124 at P 6. 73 N. Am. Elec. Reliability Corp., 183 FERC ¶ 61,116 (2023) (Order Approving Workplan). On August 16, 2023, NERC submitted its first progress update on its registration workplan. See NERC, Filing, Docket No. RD22-4-001 (filed Aug. 16, 2023). 35. The Commission also recently revised the pro forma Large Generator Interconnection Procedures (LGIP), the pro forma Large Generator Interconnection Agreement (LGIA), the pro forma Small Generator Interconnection Procedures (SGIP), and the pro forma Small Generator Interconnection Agreement (SGIA) in Order No. 2023. 74 Some of those revisions address identified deficiencies with respect to IBR modeling and ride through performance by requiring that newly interconnecting non-synchronous generators ( i.e., IBRs) (1) submit accurate and verified models with a comparable level of accuracy as synchronous generation resources and (2) configure or set control and protection settings to ride through disturbances and continue to support system reliability during abnormal frequency conditions and voltage conditions within any physical limitations of the generating facility. 75 74 See Improvements to Generator Interconnection Agreements & Procs., Order No. 2023, 88 FR 61014 (Sept. 6, 2023), 184 FERC ¶ 61,054 (2023). 75 Id. PP 1661, 1715. 36. In addition to NERC and Commission efforts, there are several voluntary industry standards and manufacturer certification efforts related to IBRs, such as the IEEE standard 2800-2022 76 for transmission connected IBRs and IEEE standard 1547-2018 77 and Underwriters Laboratory (UL) standard UL 1741 78 for distributed energy resources. These efforts are intended to enhance the operating performance and control capabilities of IBRs; however, these efforts do not apply to all relevant IBRs and require adoption by state or other regulatory authorities to become mandatory and enforceable. 79 76 IEEE, Standard for Interconnection and Interoperability of Inverter-Based Resources (IBR) Interconnecting with Associated Transmission Electric Power Systems (Apr. 22, 2022), https://standards.ieee.org/ieee/2800/10453/ (IEEE 2800-2022) (establishing uniform technical minimum requirements for the interconnection, capability, and performance of IBRs for reliable integration onto the Bulk-Power System). 77 IEEE, Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces (Feb. 15, 2018), https://standards.ieee.org/ieee/1547/5915/ (IEEE 1547-2018). The IEEE 1547-2018 and more recent 2020 amendment (IEEE 1547a-2020) of this standard enhance operating performance and control capabilities of IBR-DERs. For example, IBR-DERs compliant with the IEEE standard will be equipped with the capability to ride through voltage and frequency fluctuations in support of the reliable operation of the Bulk-Power System. 78 UL Standard 1741 Edition 3, Inverters, Converters, Controllers and Interconnection System Equipment for Use with Distributed Energy Resources Scope, https://www.shopulstandards.com/ProductDetail.aspx?UniqueKey=40673. 79 The IEEE Standards Association's board approved IEEE-2800-2022 in September 2022. See IEEE, IEEE Standard for Interconnection and Interoperability of Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, https://standards.ieee.org/ieee/2800/10453/ (explaining that IEEE-2800-2022 establishes uniform technical minimum requirements for the interconnection, capability, and lifetime performance of IBRs interconnecting with transmission and sub-transmission systems in North America). For IEEE-1547, states have made varied progress in adopting the standard. See IEEE, IEEE Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces, https://sagroups.ieee.org/scc21/standards/1547rev/; see also Odessa 2022 Disturbance Report at v (explaining that the 2022 Odessa Disturbance “is a perfect illustration of the need for immediate industry action to ensure reliable operation of the [Bulk-Power System] with increasing penetrations of inverter-based resources.”). B. Existing Reliability Standards Do Not Adequately Address IBR Reliability Risks 1. Data Sharing 37. The currently effective Reliability Standards do not require owners and/or operators of registered IBRs, transmission owners that have unregistered IBRs on their systems, or distribution providers that have IBR-DERs on their systems to provide planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities with data that accurately represents IBRs. Examples of needed data may include location; capacity; telemetry; steady-state, dynamic, and short circuit modeling information; control settings; ramp rates; equipment status; and disturbance analysis data. 80 Data that accurately represents IBRs is necessary to properly plan for, operate, and analyze IBR performance on the Bulk-Power System. 81 Without data that accurately represents all IBRs, planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities are not able to develop system models that accurately account for the behavior of IBRs on their system, nor are they able to facilitate the analysis of Bulk-Power System disturbances. 82 80 NOPR, 181 FERC ¶ 61,125 at P 27. 81 NERC has provided examples of necessary planning and operational IBR data. See, e.g., NERC, Industry Recommendation: Loss of Solar Resources during Transmission Disturbances due to Inverter Settings—II, 7-8 (May 2018), https://www.nerc.com/pa/rrm/bpsa/Alerts%20DL/NERC_Alert_Loss_of_Solar_Resources_during_Transmission_Disturbance-II_2018.pdf (Loss of Solar Resources Alert II) (describing examples of planning and operational IBR data); NERC and Texas RE, Odessa Disturbance, 20-21 (Sept. 2021), https://www.nerc.com/pa/rrm/ea/Documents/Odessa_Disturbance_Report.pdf (Odessa 2021 Disturbance Report) (covering events in Odessa, Texas on May 9, 2021 and June 26, 2021); see generally NERC and WECC, WECC Base Case Review: Inverter-Based Resources (Aug. 2020), https://www.nerc.com/comm/PC/InverterBased%20Resource%20Performance%20Task%20Force%20IRPT/NERC-WECC_2020_IBR_Modeling_Report.pdf (Western Interconnection Base Case IBR Review); NERC, Reliability Guideline: DER Data Collection for Modeling in Transmission Planning Studies (Sept. 2020), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/Reliability_Guideline_DER_Data_Collection_for_Modeling.pdf (IBR-DER Data Collection Guideline). 82 NOPR, 181 FERC ¶ 61,125 at P 28. 38. While Reliability Standard MOD-032-1 (Data for Power System Modeling and Analysis), Requirement R2 requires generator owners to submit modeling data and parameters to their transmission planners and planning coordinators, it does not require generator owners to submit registered IBR-specific modeling data and parameters such as control settings for momentary cessation and ramp rates, which are necessary for modeling steady state and dynamic registered IBR performance for purposes of planning the Bulk-Power System. 83 Nor does Reliability Standard TOP-003-5 (Operational Reliability Data) require generator owners to submit such registered IBR-specific modeling data and parameters to their transmission operators or balancing authorities. 84 83 See NERC, Technical Report, BPS-Connected Inverter-Based Resource Modeling and Studies, 35 (May 2020), https://www.nerc.com/comm/PC/InverterBased%20Resource%20Performance%20Task%20Force%20IRPT/IRPTF&_IBR_Modeling_and_Studies_Report.pdf (Modeling and Studies Report) (stating that Reliability Standard MOD-032-1 “does not prescribe the details that the modeling requirements must cover; rather, the standard requirements leave the level of detail and data formats up to each [transmission planner] and [planning coordinator] to define.”) (footnote omitted). 84 See NOPR, 181 FERC ¶ 61,125 at P 29 (referring to Reliability Standard TOP-003-4, the version of the standard enforceable at that time. Reliability Standard TOP-003-5 became mandatory and enforceable on April 1, 2023). 39. Moreover, the currently effective Reliability Standards do not ensure that Bulk-Power System planners and operators receive disturbance monitoring data regarding all generation resources capable of having a material impact on the reliable operation of the Bulk-Power System, including registered IBRs. Such data is needed to adequately assess disturbance events ( e.g., a fault on the line) and the behavior of IBRs during those events. Without adequate monitoring capability, the disturbance analysis data for a system event is insufficient to effectively determine the causes of the system event. 85 85 NERC and WECC, Multiple Solar PV Disturbances in CAISO, 13 (Apr. 2022), https://www.nerc.com/pa/rrm/ea/Documents/NERC_2021_California_Solar_PV_Disturbances_Report.pdf (2021 Solar PV Disturbances Report) (covering four events: Victorville (June 24, 2021); Tumbleweed (July 4, 2021); Windhub (July 28, 2021); and Lytle Creek (August 26, 2021)) (explaining that the “analysis team had significant difficulty gathering useful information for root cause analysis at multiple facilities . . . [and] this led to an abnormally large number of `unknown' causes of power reduction for the plants analyzed”). 40. Limitations on the availability of event data have hampered efforts by NERC, stakeholders, and industry to determine the causes of various events since 2016. In many instances, data were limited and disturbance monitoring equipment was absent because registered IBRs interconnected at lower voltages and fell below the MVA threshold. 86 These IBRs therefore did not fall within the thresholds of the currently effective Reliability Standard PRC-002-2 (Disturbance Monitoring and Reporting Requirements) Attachment 1 requirements for equipment installation. 87 Further, the absence of adequate monitoring capability leads to the potential for unreliable operation of generation resources due to the inability to effectively gather disturbance analysis data and develop mitigation strategies to either avoid or recover from abnormal resource performance during disturbance events in the future. While Reliability Standard PRC-002-2 requires the installation of disturbance monitoring equipment at certain key nodes ( e.g., stability limited interfaces), and such limited placements have been adequate to provide the data necessary to analyze major system events in the past, NERC has found that the existing disturbance monitoring equipment is not sufficient ( e.g., lack of high speed data captured at the IBR or plant level controller and low resolution time stamping of inverter sequence of event recorder information) to analyze the widespread system events that have become more common since 2016. 88 86 NERC, Improvements to Interconnection Requirements for BPS-Connected Inverter-Based Resources, at 1 (Sept. 2019) (IBR Interconnection Requirements Guideline) (reporting that the majority of newly interconnecting IBRs are either connecting at voltages less than 100 kV or with capacity less than 75 MVA and therefore do not meet the size criteria in the bulk electric system definition). NERC's Commission-approved bulk electric system definition is a subset of the Bulk-Power System and defines the scope of the Reliability Standards and the entities subject to NERC compliance. Revisions to Electric Reliability Org. Definition of Bulk Elec. Sys. & Rules of Proc., Order No. 773, 141 FERC ¶ 61,236 (2012) order on reh'g, Order No. 773-A (May 17, 2013), 143 FERC ¶ 61,053 (2013), rev'd sub nom. People of the State of N.Y. v. FERC, 783 F.3d 946 (2d Cir. 2015); NERC Glossary at 7-9. 87 NOPR, 181 FERC ¶ 61,125 at P 32; see also Reliability Standard PRC-002-2, Requirement R5.1.1 (specifying dynamic disturbance recording data for generation resource(s) with gross individual nameplate rating greater than or equal to 500 MVA, and gross individual nameplate rating greater than or equal to 300 MVA where the gross plant/facility aggregate nameplate rating is greater than or equal to 1,000 MVA). 88 See NOPR, 181 FERC ¶ 61,125 at P 32 n.74 (citing NERC and WECC, April and May 2018 Fault Induced Solar Photovoltaic Resource Interruption Disturbances Report, 23 (Jan. 2019), https://www.nerc.com/pa/rrm/ea/April_May_2018_Fault_Induced_Solar_PV_Resource_Int/April_May_2018_Solar_PV_Disturbance_Report.pdf (Angeles Forest and Palmdale Roost Events Report) (covering the Angeles Forest (April 20, 2018) and Palmdale Roost (May 11, 2018) events and explaining that the “widespread nature of power reduction across many facilities poses risks to [Bulk-Power System] performance and reliability” and finding that the “lack of available high-speed data at multiple inverter-based resources has hindered event analysis”); San Fernando Disturbance Report at 7; Odessa 2021 Disturbance Report at 11; NERC, Odessa Disturbance Follow-up White Paper (Oct. 2021), https://www.nerc.com/comm/RSTC_Reliability_Guidelines/White_Paper_Odessa_Disturbance_Follow-Up.pdf (Odessa Disturbance White Paper)). 41. The currently effective Reliability Standards do not require Bulk-Power System planners and operators to receive modeling data and parameters regarding unregistered IBRs that, individually or in the aggregate, are capable of adversely affecting the reliable operation of the Bulk-Power System. Further, the currently effective Reliability Standards do not require that Bulk-Power System planners and operators receive modeling data and parameters that accurately represent IBR-DERs that in the aggregate have a material impact on the reliable operation of the Bulk-Power System. 89 As shown by various reports and guidelines, 90 Bulk-Power System planners and operators do not currently have the data to accurately model the behavior of registered and unregistered IBRs individually and in the aggregate, and IBR-DERs in the aggregate, for steady-state, dynamic, and short circuit studies. 89 See NOPR, 181 FERC ¶ 61,125 at P 80 (stating that distribution providers should be permitted to provide IBR-DER modeling data and parameters “in the aggregate or equivalent for IBR-DERs interconnected to their distribution systems ( e.g., IBR-DERs in the aggregate and modeled by resource type such as wind or solar PV, or IBR-DERs in the aggregate and modeled by interconnection requirements performance to represent different steady-state and dynamic behavior.”); see also id. n.159 (explaining that for IBR-DERs “a certain degree of simplification may be needed either by model aggregation ( i.e., clustering of models with similar performance), by derivation of equivalent models ( i.e., reduced-order representation), or by a combination of the two.”). 90 See, e.g., Commission Staff, Distributed Energy Resources Technical Considerations for the Bulk Power System Staff Report, Docket No. AD18-10-000, 11-13 (filed Feb. 15, 2018) (Commission Staff IBR-DER Reliability Report) (explaining that, absent adequate data, many Bulk-Power System models and operating tools will not fully represent the effects of IBR-DERs in aggregate); see also IBR-DER Data Collection Guideline at 2 (recommending that transmission planners and planning coordinators update their data reporting requirements for Reliability Standard MOD-032-1, Requirement R1 to explicitly describe the requirements for aggregate IBR-DER data in a manner that is clear and consistent with their modeling practices. The IBR-DER Data Collection Guideline also recommended that transmission planners and planning coordinators establish modeling data requirements for steady-state IBR-DERs in aggregate and coordinate with their distribution providers to develop these requirements.). 2. Data and Model Validation 42. Bulk-Power System planners and operators need accurate planning, operations, and interconnection-wide models to ensure the reliable operation of the Bulk-Power System. Bulk-Power System planners and operators use electrical component models to build the generation, transmission, and distribution facility models that they combine to build their transmission area model. These models are further combined with those of their neighbors to form the interconnection-wide models, which are used to analyze the reliability of the interconnected transmission system. 91 Each of the planning, operations, and interconnection-wide models consist separately of steady state, dynamic, and short circuit models. 91 See Reliability Standard MOD-033-2 (Steady-State and Dynamic System Model Validation). 43. Without planning, operations, and interconnection-wide models that accurately reflect resource ( e.g., generation and load) behavior in steady state and dynamic conditions, Bulk-Power System planners' and operators' system models 92 are unable to adequately predict resource behavior, including momentary cessation from both registered and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate, and their subsequent impacts on the Bulk-Power System. 93 92 This final action uses the term “system models” to refer collectively to planning and operations transmission area models and interconnection-wide models. 93 See IBR Interconnection Requirements Guideline at 24 (stating that a systemic modeling issue was uncovered regarding the accuracy of the IBR dynamic models submitted in the interconnection-wide base cases following the issuance of the NERC Alert related to the Canyon 2 Fire disturbance). 44. The currently effective Reliability Standards do not require the use of NERC's approved component models; 94 instead, models are referred to generally in Reliability Standard MOD-032-1, Attachment 1. 95 Without requirements to use approved component models in Bulk-Power System planning and operations system models, resource owners may provide modeling data that is based on a user-defined model 96 rather than an approved and industry-vetted model. 97 The use of user-defined models in system models can be problematic because their internal model components cannot be viewed or modified, and thus they produce outputs that cannot be readily explained or verified. 98 Approved generator models that accurately reflect the generator behavior in steady state and dynamic conditions are necessary for Bulk-Power System planners and operators to adequately predict IBR behavior and the subsequent impact of IBRs on the Bulk-Power System. 99 94 NERC, Libraries of Standardized Powerflow Parameters and Standardized Dynamics Models version 1, 1 (Oct. 2015), https://www.nerc.com/comm/PC/Model%20Validation%20Working%20Group%20MVWG%202013/NERC%20Standardized%20Component%20Model%20Manual.pdf (NERC Standardized Powerflow Parameters and Dynamics Models) (explaining that the NERC Modeling Working Group was tasked to develop, validate, and maintain a library of standardized component models and parameters for short-circuit, powerflow, and dynamics cases. The standardized models in these libraries have documentation describing their model structure, parameters, and operation. This information has been vetted by the industry and thus deemed appropriate for widespread use in planning, operations, and interconnection-wide analysis.). 95 See Reliability Standard MOD-032-1, attach. 1 (explaining that if a user-written model(s) is submitted in place of a generic or library model, it must include the characteristics of the model, including block diagrams, values, and names for all model parameters, and a list of all state variables). 96 Some commenters use the term “proprietary” to describe user-defined models. For purposes of this final action, the terms “proprietary” and “user-defined” models are synonymous. A user-defined model is a unique manufacturer-specific model that does not appear on the NERC approved component model list. In Order No. 2023, the Commission defined a “user-defined model” as any set of programming code created by equipment manufacturers or developers that captures the latest features of controllers that are mainly software-based and represents the entities' control strategies but does not necessarily correspond to any particular generic library model. See Order No. 2023, 184 FERC ¶ 61,054 at P 1660. 97 NERC Standardized Powerflow Parameters and Dynamics Models at 1 (explaining that “[s]ome of the model structures have information that is considered to be proprietary or confidential, which impedes the free flow of information necessary for interconnection‐wide power system analysis and model validation.”); see also NERC, Events Analysis Modeling Notification Recommended Practices for Modeling Momentary Cessation Initial Distribution, 1 n.4 (Feb. 2018), https://www.nerc.com/comm/PC/NERCModelingNotifications/Modeling_Notification_-_Modeling_Momentary_Cessation_-_2018-02-27.pdf (explaining that more detailed vendor-specific models may be used for local planning studies; however, they are generally not allowed or recommended for building interconnection-wide models). 98 See, e.g., EPRI, Model User Guide for Generic Renewable Energy System, 2 (June 2015), https://www.epri.com/research/products/000000003002006525 (explaining that the “models presented here were developed primarily for the purpose of general public use and benefit and to eliminate the long standing issues around many vendor-specific models being proprietary and thus neither publicly available nor easily disseminated among the many stakeholders. Furthermore, using multiple user-defined non-standard models within large interconnection studies, in many cases, presented huge challenges and problems with effectively and efficiently running the simulations.”). 99 NERC Standardized Powerflow Parameters and Dynamics Models at 1 (explaining that there is a growing need for accurate interconnection‐wide power flow and dynamics simulations that analyze phenomena such as: frequency response, inter-area oscillations, and interactions between the growing numbers of wide-area control and protections systems). 45. Any generation resource model's performance must be verified by the generator owner using real-world data to confirm that the generation resource model adequately reflects actual as-built settings, historic performance, and/or field-testing data. 100 The currently effective Reliability Standards MOD-026-1 (Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions) 101 and MOD-027-1 (Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions) 102 require each generator owner to verify models and data for specific components of synchronous resources ( e.g., generator excitation control systems, plant volt/var control functions, turbine/governor and load controls, and active power/frequency controls), but they do not require a generator owner to provide verified models and data for IBR-specific controls ( e.g., power plant central controller functions and protection system settings) to its transmission planner. Additionally, the currently effective Reliability Standards neither require the transmission owner for unregistered IBRs to provide verified dynamic models nor require distribution providers to provide verified dynamic models of IBR-DERs in the aggregate to their transmission planners. Finally, the currently effective Reliability Standards neither require the transmission owner for unregistered IBRs nor the distribution providers for IBR-DERs in the aggregate to submit the respective dynamic models to the applicable registered entities that perform planning and operations functions. 100 Id. (explaining that the NERC Modeling Working Group was tasked to develop, validate, and maintain a library of standardized component models and parameters for powerflow and dynamics cases. The standardized models in these libraries have documentation describing their model structure, parameters, and operation. This information has been vetted by the industry and thus deemed appropriate for widespread use in interconnection‐wide analysis). 101 See Reliability Standard MOD-026-1. 102 See Reliability Standard MOD-027-1. 46. Once the generator owners for registered IBRs, transmission owners for unregistered IBRs, and distribution providers for IBR-DERs in the aggregate verify plant models, Bulk-Power System planners and operators must validate and update system models ( i.e., planning and operation transmission area models as well as interconnection-wide models) by comparing the provided data and resulting system models against actual system operational behavior. While Reliability Standard MOD-033-2 (Steady State and Dynamic System Model Validation) requires validation using real-world data of the interconnection-wide model, 103 the currently effective Reliability Standards lack clarity as to whether models of registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate are required to represent the real-world behavior of the equipment installed in the field during interconnection-wide disturbances that have exhibited common mode failures of IBRs. 104 103 Reliability Standard MOD-033-2, Requirements R1, R2. 104 NERC annually assesses the interconnection-wide model quality and publishes a report to help entities responsible for complying with Reliability Standard MOD-032 to resolve model issues and improve the cases. NERC's 2021 Case Quality Metrics Assessment indicates that planners are not able to develop accurate system models ( e.g., all interconnections demonstrate either a consistent performance or worsening score in the unacceptable or not recommended model metrics). See NERC, Case Quality Metrics Annual Interconnection-wide Model Assessment, 26-29 (Oct. 2021), https://www.nerc.com/pa/RAPA/ModelAssessment/ModAssessments/2021_Case_Quality_Metrics_Assessment-FINAL.pdf. 47. Once Bulk-Power System planners and operators validate system models, 105 there must be additional requirements for generator owners, transmission owners, and distribution providers to communicate with Bulk-Power System planners and operators to ensure that any changes to IBR settings, configurations, and ratings are updated. Otherwise, the transmission system models will not adequately represent the behavior of the actual installed equipment. 106 While Reliability Standards MOD-032-1 and MOD-033-2 include iterative updating and validation processes, Reliability Standard MOD-032-1 does not require IBR-specific modeling data and parameters, and Reliability Standard MOD-033-2 does not contemplate the technology-specific performance characteristics of registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate. 105 This final action uses “validation” to mean the confirmation that a model reflects real world operational behaviors and uses “verification” to mean a model is properly parameterized and validated. 106 See NOPR, 181 FERC ¶ 61,125 at P 39 n.91. 48. Once Bulk-Power System planners and operators have validated system models, Bulk-Power System planners and operators need to coordinate with generator owners, transmission owners, and distribution providers so that the system models adequately represent all generation resources—including registered IBRs, unregistered IBRs, IBR-DERs in the aggregate, and synchronous generation—as well as load. Reliability Standards MOD-032-1 and MOD-033-2 do not require the applicable entities to work collaboratively to create interconnection-wide models that accurately reflect the real-world interconnection-wide performance and behavior of registered and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate. 107 As a result, the models developed and deployed in compliance with these standards do not contemplate that IBRs can reduce power, trip offline, or enter momentary cessation individually or in the aggregate in response to a single fault on a transmission or sub-transmission system. 107 Reliability Standard MOD-032-1 is applicable to the following registered entities: (1) balancing authorities, (2) generator owners, (3) planning authorities/planning coordinators, (4) load serving entity, (5) resource planners, (6) transmission owners, (7) transmission planners, and (8) transmission service providers. NERC has deregistered the load serving entity function and has an ongoing standard drafting team project to replace this function as an applicable entity in the Reliability Standards with the distribution provider function. See Project-2022-02 Modifications to TPL-001 and MOD-032. 3. Planning and Operational Studies 49. Once Bulk-Power System planners and operators have validated registered IBR, unregistered IBR, and IBR-DER aggregate modeling and operational data, the Reliability Standards must require that Bulk-Power System planning and operational studies account for the actual behavior of both registered IBRs and unregistered IBRs individually and in the aggregate, as well as IBR-DERs in the aggregate. The Reliability Standards do not require Bulk-Power System planning and operational studies to assess the performance and behavior of both registered and unregistered IBRs individually and in the aggregate ( e.g., IBRs tripping or entering momentary cessation individually or in the aggregate), as well as IBR-DERs in the aggregate. Reliability Standard TPL-001-5.1 (Transmission System Planning Performance Requirements) requires planning coordinators and transmission planners to plan to ensure reliable operations over a broad spectrum of system conditions and following a wide range of probable contingencies, but it does not require planning coordinators and transmission planners to assess the performance and behavior of registered and unregistered IBRs individually and in the aggregate, or IBR-DERs in the aggregate, during normal and contingency conditions for the reliable operation of the Bulk-Power System. 108 NERC has stated that the currently effective Reliability Standards do not mitigate the IBR reliability risks because the IBR issues are not properly detected by models and studies. 109 NERC has also found that there is an immediate need to enhance the currently effective Reliability Standards. NERC explains that there is a need to understand the extent of inverter performance risks and modeling deficiencies as well as to gather necessary data for the currently installed fleet. 110 108 Reliability Standard TPL-001-5.1 (Transmission System Planning Performance Requirements) was approved by the Commission and became effective on July 1, 2023. See N. Am. Elec. Reliability Corp., Docket No. RD20-8-000 (June 10, 2020) (delegated letter order) (approving a NERC-proposed erratum to Reliability Standard TPL-001-5); Transmission Plan. Reliability Standard TPL-001-5, Order No. 867, 170 FERC ¶ 61,030 (2020) (approving Reliability Standard TPL-001-5). 109 See Odessa 2021 Disturbance Report at 43 (explaining that “[p]lants are abnormally responding to [Bulk-Power System] disturbance events and ultimately tripping themselves off-line. These issues are not being properly detected by the models and studies conducted during the generator interconnection study process nor during annual planning assessments.”). 110 Odessa 2022 Disturbance Report at vii-ix. 4. Performance Requirements 50. The currently effective Reliability Standards do not account for the differences in response of registered IBRs and synchronous generation resources during normal and contingency conditions. The frequency of an interconnection depends on the instantaneous balance between load and generation resources, to which all resources contribute during both normal and contingency conditions. For frequency to be maintained, generation resources must remain connected to the grid and continue to support grid frequency ( i.e., ride through) during either loss of generation (underfrequency) or loss of load (overfrequency) related frequency deviations. Reliability Standard PRC-024-3 does not require registered IBRs (or any generator) to remain connected to the Bulk-Power System and to continue to inject current and support frequency inside the “no trip zone.” 111 Therefore, IBRs could continue to act adversely in response to normally cleared faults by continuing to exhibit momentary cessation and power reduction behaviors. 111 Reliability Standard PRC-024-3 is a voltage and frequency protection settings standard that specifies that a generating resource may neither trip nor enter momentary cessation ( i.e., cease injecting current) inside the boundaries of the frequency and voltage excursion curves. The area inside the boundaries of the frequency and voltage excursion curves is known as the “no-trip zone.” See also Reliability Standard PRC-024-3, attach. 1, nn.8, 9. 51. In addition, the currently effective Reliability Standards do not require registered IBRs to continually inject current and support voltage inside the “no trip zone” during a voltage excursion. 112 The Reliability Standards also do not contain voltage ride through performance requirements that address the unique protection and control functions of registered IBRs that can cause tripping and momentary cessation, even when the IBR voltage protection settings comply with Reliability Standard PRC-024-3. 112 The NOPR used both terms current and power when proposing to direct NERC to develop new or modified Reliability Standards that address registered IBRs' performance requirements. For clarity in this final action, we only use “current” when directing NERC to develop new or modified Reliability Standards that address registered IBRs' performance requirements. 52. Finally, the currently effective Reliability Standards do not require all generation resources that momentarily cease operation following a system disturbance to return to pre-disturbance output levels without impeded ramp rates or require that all generation resources maintain voltage phase angle synchronization with the Bulk-Power System grid voltage during a system disturbance. IBRs that lose synchronization with grid voltage ( i.e., phase lock loop loss of synchronism) will momentarily cease current injection into the grid during Bulk-Power System disturbance events due to protection and control settings. Such momentary cessation occurrences exacerbate system disturbances and have a material impact on the reliable operation of the Bulk-Power System. 113 113 See NOPR, 181 FERC ¶ 61,125 at P 4. IV. Discussion 53. As discussed below, the Commission finds that the currently effective Reliability Standards do not adequately address the risks posed by the increasing numbers of IBRs connecting to the Bulk-Power System. As noted by NERC in its initial comments, IBRs can introduce significant risks to the Bulk-Power System if not integrated properly, and NERC sees addressing such risks as a high priority for the ERO. 114 While NERC has initiated various projects to address aspects of IBR reliability, we find that the actions we take in this final action are necessary to maintain the reliable operation of the Bulk-Power System. Accordingly, pursuant to section 215(d)(5) of the FPA, we adopt the NOPR proposals with some modifications and direct NERC to develop and submit new or modified Reliability Standards that address the impacts of IBRs on the reliable operation of the Bulk-Power System. Given the current and projected increase in the proportion of IBRs within the Bulk-Power System generation fleet, and for the reasons discussed in section III above, we conclude that it is necessary to direct NERC to develop new or modified Reliability Standards that address the following specific matters: (1) generator owner data sharing for registered IBRs, transmission owner data sharing for unregistered IBRs, and distribution provider data sharing for IBR-DERs in the aggregate; (2) data and model validation for registered and unregistered IBRs and IBR-DERs in the aggregate; (3) planning and operational studies for registered and unregistered IBRs individually and in the aggregate and for IBR-DERs in the aggregate; and (4) registered IBR performance requirements. 114 NERC Initial Comments at 2. 54. In directing the ERO to submit new or modified Reliability Standards, we do not direct a specific method for addressing the reliability concerns discussed herein. Rather, in this final action we identify issues that should be addressed in the NERC standards development process. Further, NERC has the discretion, subject to Commission review and approval, as to how to address the reliability concerns described below by developing one or more new Reliability Standards or modifying currently effective Reliability Standards. We direct NERC to develop new or modify the currently effective Reliability Standards to address these issues and, when these Reliability Standards are submitted to the Commission for approval, to explain in the accompanying petition how the issues are addressed in the proposed new or modified Reliability Standards. NERC may propose to develop new or modified Reliability Standards that address our concerns in an equally efficient and effective manner; however, NERC's proposal should explain how the new or modified Reliability Standards address the Commission's concerns discussed in this final action. 115 115 See, e.g., Order No. 693, 118 FERC ¶ 61,218 at PP 186, 297. 55. We modify the NOPR proposal and direct NERC to submit an informational filing within 90 days of the issuance of the final action in this proceeding that includes a detailed, comprehensive standards development plan explaining how NERC will prioritize the development of new or modified Reliability Standards to meet the deadlines set out below, taking into account the risk posed to the reliability of the Bulk-Power System, standard development projects already underway, resource constraints, and other factors if necessary. 56. As discussed below, we are persuaded by commenters' suggestions regarding the proposed staggered groupings for new or modified Reliability Standards, and we modify the NOPR proposal to adopt NERC's proposed staggered grouping that would result in NERC submitting new or modified Reliability Standards in three stages. 116 Therefore, in its comprehensive standards development plan, NERC must submit new or modified Reliability Standards by the following deadlines. First, by November 4, 2024, NERC must submit new or modified Reliability Standards that establish IBR performance requirements, including frequency and voltage ride through, post-disturbance ramp rates, phase lock loop synchronization, and other known causes of IBR tripping or momentary cessation. NERC must also submit, by November 4, 2024, new or modified Reliability Standards that require disturbance monitoring data sharing and post-event performance validation for registered IBRs. Second, by November 4, 2025, NERC must submit new or modified Reliability Standards addressing the interrelated directives concerning: (1) data sharing for registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate; and (2) data and model validation for registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate. Finally, by November 4, 2026, NERC must submit new or modified Reliability Standards addressing planning and operational studies for registered IBRs, unregistered IBRs, and IBR-DER in the aggregate. NERC may expedite its development plan and submit new or modified Reliability Standards prior to the deadlines. 116 In the NOPR, the Commission proposed a staggered approach that would result in NERC submitting new or modified Reliability Standards in three stages. See NOPR, 181 FERC ¶ 61,125 at PP 8, 73. In the final action, we are changing the content of the three staggered filings. 57. While the NOPR proposed directing NERC to include implementation dates ( i.e., when the standards would become mandatory and enforceable) in its standards development plan, we are persuaded by NERC's comments that the implementation of new or modified Reliability Standards is better determined through the NERC standards drafting process. Therefore, we do not adopt the NOPR proposal to direct NERC to include implementation dates in its standards development plan. Rather, the Commission will consider the justness and reasonableness of each new or modified Reliability Standard's implementation plan when it is submitted for Commission approval. 117 However, as discussed above, the number of events, NERC Alerts, reports, whitepapers, guidelines, and ongoing standards projects demonstrate the need for the expeditious implementation of new or modified Reliability Standards addressing IBR data sharing, data and model validation, planning and operational studies, and performance requirements. 118 Accordingly, the Commission will take these issues into account when it considers the proposed implementation plan for each new or modified Reliability Standard when it is submitted to the Commission for review. Moreover, as a general matter, we believe that there is a need to have all of the directed Reliability Standards effective and enforceable well in advance of 2030, at which time IBRs are projected to account for a significant share of the electric energy generated in the United States. 119 117 See Order No. 672, 114 FERC ¶ 61,104 at P 333 (“In considering whether a proposed Reliability Standard is just and reasonable, the Commission will consider also the timetable for implementation of the new requirements, including how the proposal balances any urgency in the need to implement it against the reasonableness of the time allowed for those who must comply.”). 118 See supra P 7. 119 See, e.g., U.S. Energy Information Admin., Annual Energy Outlook 2023 (Mar. 16, 2023), https://www.eia.gov/outlooks/aeo/narrative/index.php#TheElectricityMixinth (projecting that renewables will account for a significant portion of the electric energy generated in the United States by 2030). The U.S. Energy Industry Association defines the major types of renewable energy sources to include resources such as biomass, hydropower, geothermal, wind, and solar ( e.g., Stirling cycle, solar PV, and concentric solar). See https://www.eia.gov/energyexplained/renewable-sources/. Of these resources, solar PV and wind generation are IBRs. 58. We address below in further detail issues raised in the NOPR and in comments regarding: (A) Commission authority to direct the ERO to develop new or modified Reliability Standards under FPA section 215(d)(5); (B) data sharing, including registered IBR data, disturbance monitoring data, unregistered IBR data, and data for IBR-DERs in the aggregate; (C) data and model validation, including approved models, dynamic model performance, validation of system models, and coordination; (D) planning and operational studies; (E) performance requirements; and (F) the informational filing and associated timeline for Reliability Standard development. A. Commission Authority To Direct the ERO To Develop New or Modified Reliability Standards Under Section 215 of the FPA 59. In the NOPR, the Commission preliminarily found that the currently effective Reliability Standards do not adequately address the impacts of IBRs on the reliable operation of the Bulk-Power System. 120 The NOPR stated that this constitutes a reliability gap in the areas of: (1) data sharing; (2) model validation; (3) planning and operational studies; and (4) performance requirements. To carry out section 215 of the FPA, the NOPR proposed to direct NERC to develop and submit for approval new or modified Reliability Standards that address IBRs and their impacts on the reliable operation of the Bulk-Power System. 120 NOPR, 181 FERC ¶ 61,125 at P 68. 1. Comments 60. NERC supports the Commission's efforts and agrees that the currently effective Reliability Standards must be enhanced to address the reliability risks posed by IBRs. 121 Further, NERC and the majority of commenters that responded on this topic generally support the four topic areas for new or modified Reliability Standards ( i.e., data sharing, model validation, planning and operational studies, and performance requirements) that the Commission outlined in the NOPR. 122 121 NERC Initial Comments at 7. 122 See, e.g., id.; AEP Initial Comments at 2; Bonneville Initial Comments at 1; CAISO Initial Comments at 1; NYSRC Initial Comments at 1. 61. Commenters agree that IBRs affect the reliable operation of the Bulk-Power System and that some modifications to the currently effective Reliability Standards are warranted. 123 For example, IRC states that IBRs may have an impact on the reliability of the Bulk-Power System regardless of their size, registration status, or their interconnection level ( i.e., connected to transmission or distribution). 124 ACP/SEIA agree there is a need for clarity and consistency for IBRs and their Reliability Standard obligations. 125 EPRI states that its research and collaboration has shown that uniform technical performance requirements, including ride through requirements, can support system reliability. 126 Indicated Trade Associations agree that it is necessary to manage the impact of the increase of IBRs on the Bulk-Power System through new or modified Reliability Standards. 127 123 See, e.g., AEU Initial Comments at 2 (agreeing the IBRs may cause adverse reliability impacts and contribute reliability benefits to the Bulk-Power System); InfiniRel Initial Comments at 1 (stating that “[n]ew or modified Reliability Standards are necessary to address the IBR-related reliability gaps”). 124 IRC Initial Comments at 2. 125 ACP/SEIA Initial Comments at 4. 126 EPRI Initial Comments at 4. 127 Indicated Trade Association Comments at 1. 62. Ohio FEA, noting that the majority of IBR-related events discussed in the NOPR predominantly took place in Texas and California, defers to the Commission's findings regarding gaps in the currently effective Reliability Standards for IBRs and emphasizes that it is the Commission's role within its FPA section 215 authority to protect Bulk-Power System reliability by directing NERC to develop new or modified Reliability Standards. 128 Nevertheless, Ohio FEA also notes that the definition of “Bulk-Power System” does not include facilities used in the local distribution of electric energy; and Ohio FEA emphasizes that there is a dividing line between the Commission's authority over the Bulk-Power System and its authority over its distribution system. 129 Further, Ohio FEA cautions that there could be potential conflicts in the reliability objectives, standards, and guidelines related to IBRs on the transmission system versus the distribution system. 130 128 Ohio FEA Initial Comments at 4. 129 Id. at 5. 130 Ohio FEA notes that transmission system operators prefer generators to ride-through short duration transmission faults, while distribution system operators typically prefer generators to trip off during distribution faults. Ohio FEA Initial Comments at 6. 2. Commission Determination 63. We find that the directives in this final action are a valid exercise of the Commission's authority pursuant to FPA section 215(d)(5). The plain language of the statute authorizes the Commission to order the development of a Reliability Standard that “addresses a specific matter if the Commission considers such a new or modified Reliability Standard appropriate to carry out this section.” 131 131 16 U.S.C. 824o(d)(5). 64. We determine that directing NERC, as the ERO, to address the specific matters pertaining to IBRs and their impact on the reliable operation of the Bulk-Power System is appropriate to carry out FPA section 215. As the NOPR stated, and as discussed in section III above, there are multiple ERO findings of the reliability impacts of IBRs, including guidelines, white papers, assessments, event reports, and NERC Alerts, among others. Further, NERC has already begun efforts to address IBR reliability issues through projects to improve the mandatory Reliability Standards. 132 As Bulk-Power System events continue to occur and the risks that IBRs can pose to reliable operation of the Bulk-Power System are demonstrated, there is an urgent need to develop and implement mandatory Reliability Standards to address these issues on a nationwide basis. 132 See supra P 32. 65. Section 215 of the FPA defines “reliability standard” as a requirement to provide for reliable operation of the Bulk-Power System. 133 FPA section 215 defines “reliable operation” to mean operating Bulk-Power System elements within their thermal, voltage, and stability limits to prevent or avoid instability, uncontrolled separation, or cascading failures as a result of a sudden disturbance, including a cybersecurity incident, or unanticipated failure of system elements. 134 We are aware of the Commission's jurisdictional boundaries as noted by Ohio FEA. Thus, the directives in this final action are to NERC as the ERO to develop new or modified Reliability Standards to require the reliable operation of the Bulk-Power System. While certain directives pertain to registered entities such as distribution providers obtaining aggregate data for IBR-DERs, the final action does not impose any requirements on non-registered entities or facilities used in the local distribution of electric energy. 135 Regarding Ohio FEA's concerns about the need for coordination between transmission system operators and distribution providers regarding their different performance requirements, 136 as the Commission has explained, the IBR Registration Order and NERC's related work plan do not address the registration of IBR-DERs. 137 NERC has committed to examine potential impacts of IBR-DERs on the reliable operation of the Bulk-Power System; thus, we would expect that as a part of NERC's communication plan it would consider how to address related coordination issues between transmission operators and distribution providers. 138 133 16 U.S.C. 824o(a)(3). 134 Id. 824o(a)(4). 135 Id. 824o(a)(1). 136 Ohio FEA notes that transmission system operators prefer generators to ride-through short duration transmission faults, while distribution system operators typically prefer generators to trip off during distribution faults. Ohio FEA Initial Comments at 6. 137 See Order Approving Workplan, 183 FERC ¶ 61,116 at P 48 (citing IBR Registration Order, 181 FERC ¶ 61,124 at P 1 n.1 (stating that the order does not address IBRs connected to the distribution system)). See also id. P 1 n.2 (citing 16 U.S.C. 824o(a)(1), which explains that the term “Bulk-Power System” does not include facilities used in the local distribution of electric energy). 138 See Id. P 15 (explaining that NERC's communication plan outlines how NERC will coordinate with key stakeholders). B. Data Sharing 66. In the NOPR, the Commission preliminarily found that the existing Reliability Standards are inadequate to ensure that sufficient data of registered IBRs and unregistered IBRs, and data of IBR-DERs in the aggregate, are provided to the registered entities responsible for planning, operating, and analyzing disturbances on the Bulk-Power System. 139 The Commission observed that the currently effective Reliability Standards, such as TOP-003-5 (Operational Reliability Data) and IRO-010-4 (Reliability Coordinator Data Specification and Collection), 140 require the data recipient to specify a list of data to be provided, and obligates other identified registered entities to provide the specified data. The Commission preliminarily found that these and other currently effective data-related Reliability Standards do not require generator owners, generator operators, transmission owners, and distribution providers to provide data that represents the behavior of both registered and unregistered IBRs individually and in the aggregate, as well as data of IBR-DERs in the aggregate, at a sufficient level of fidelity for Bulk-Power System planners and operators to accurately plan for, operate during, and analyze disturbances on the Bulk-Power System. 141 139 NOPR, 181 FERC ¶ 61,125 at P 76. 140 Reliability Standard TOP-003-5 and Reliability Standard IRO-010-4 became effective April 1, 2023. 141 NOPR, 181 FERC ¶ 61,125 at P 76. 67. To address this data sharing gap in the currently effective Reliability Standards, the Commission proposed to direct NERC to develop new or modified Reliability Standards that identify: (1) the registered entities that must provide certain data of registered IBRs and unregistered IBRs, as well as IBR-DER data in the aggregate; (2) the recipients of that registered IBR, unregistered IBR, and IBR-DER in the aggregate data; (3) the minimum categories or types of registered IBR, unregistered IBR, and IBR-DER in the aggregate related data that must be provided; and (4) the timing and periodicity for the provision of registered IBR, unregistered IBR, and IBR-DER in the aggregate data needed for modeling, operations, and disturbance analysis to the appropriate registered entities and the review of that data by those entities. 142 142 Id. P 77. 1. Registered IBR Data Sharing 68. In the NOPR, the Commission proposed to direct NERC to develop new or modified Reliability Standards that require generator owners and generator operators of registered IBRs to provide registered IBR-specific modeling data and parameters ( e.g., steady-state, dynamic, and short circuit modeling information, and control settings for momentary cessation and ramp rates) that accurately represents IBRs to their planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities that are responsible for planning and operating the Bulk-Power System. 143 The Commission explained that this approach would provide the registered entities responsible for planning and operating the Bulk-Power System with accurate data on registered IBRs. 144 143 Id. P 78. 144 Id. a. Comments 69. Commenters generally support the proposed directive to require IBR generator owners and generator operators to provide registered IBR-specific modeling data and parameters to planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities. 145 145 See, e.g., NERC Initial Comments at 8; CAISO Initial Comments at 24. 70. NERC states that poor or inadequate IBR data, models, and information have proven to be a significant issue. For example, generator owners may provide modeling data and information that is generic or based on default parameters that do not reflect the as-built facility. 146 NERC states that providing adequate modeling data and information is critical to create and maintain models that represent necessary modeling data quality and accuracy, adding that data accuracy, completeness, usability, and fidelity should be explicitly defined, tested, and verified by all applicable entities, particularly for modeling information used in reliability studies. 147 146 NERC Initial Comments at 8. 147 Id. at 8-9. 71. Indicated Trade Associations and APS explain that the currently effective Reliability Standards may not ensure that transmission planners or operators have all necessary criteria and metrics to plan for and reliably integrate certain IBRs on the Bulk-Power System. 148 CAISO explains that its experience shows that modern IBRs are capable of complying with data sharing and data and model validation requirements. 149 Further, CAISO supports national standards establishing data sharing, and data and model validation guidelines, as a patchwork approach would be inefficient ( e.g., a significant number of IBRs participating in the CAISO's markets are not bound by the currently effective Reliability Standards and CAISO's standards do not bind across the Western Electricity Coordinating Council). 150 148 Indicated Trade Associations Initial Comments at 4-5; APS Initial Comments at 2 (indicating it largely supports Indicated Trade Associations Initial Comments but providing additional comments on specific topics). 149 CAISO Initial Comments at 7. 150 Id. at 30-31. 72. SPP states that it has heard from IBR owners that they have concerns that some IBR data (and IBR-DER data) may be considered proprietary by manufacturers and difficult to obtain. Nevertheless, SPP contends that such concerns should not obstruct reliability improvements and suggests that the final action should provide the correct incentive for IBR owners to either use equipment that meets data sharing requirements ( i.e., equipment that is not proprietary) or develop agreements or other protections for IBR data that is considered proprietary. 151 151 SPP Initial Comments at 2. 73. ACP/SEIA suggest modifying the directives to require generator owners and operators to share IBR data. ACP/SEIA recommend that, rather than mandating specific modeling and data submissions, planning entities should have flexibility to identify the data they need for their operations and planning activities, and that the new or modified Reliability Standards should ensure that the data requested is reasonable and necessary for improving reliability. 152 152 ACP/SEIA Initial Comments at 11-12. 74. AEU and ACP/SEIA ask that, in addition to data provision requirements for generator owners and operators, the Commission direct NERC to specify data sharing requirements from transmission owners to generator owners. 153 For example, AEU explains that generator owners and operators also require data from transmission owners to support accurate modeling and performance, e.g., short circuit data, grid data for offshore wind, information on other power electronic devices around the IBR plant, and voltage harmonics. 154 AEU adds that putting requirements on transmission owners would be consistent with revisions being developed for NERC's Modeling, Data, and Analysis (MOD) Reliability Standards. 155 153 AEU Initial Comments at 4; ACP/SEIA Initial Comments at 12-13. 154 AEU Initial Comments at 4. 155 Id. at 5. 75. ACP/SEIA, Mr. Plankey, and Ohio FEA raise security concerns and the need for accountability and protection of data sharing. 156 Ohio FEA recommends that NERC's Electricity Information Sharing and Analysis Center (E-ISAC) could serve as a facilitator for IBR data sharing. 157 156 ACP/SEIA Initial Comments at 12; Mr. Plankey Initial Comments at 1; Ohio FEA Initial Comments at 9. 157 Ohio FEA Initial Comments at 9. b. Commission Determination 76. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR proposal and direct NERC to develop new or modified Reliability Standards that require registered IBR generator owners and operators to provide IBR-specific modeling data and parameters ( e.g., steady-state, dynamic, and short circuit modeling information, and control settings for momentary cessation and ramp rates) that accurately represent the registered IBRs to their planning coordinators, transmission planners, reliability coordinators, transmission operators, and balancing authorities that are responsible for planning and operating the Bulk-Power System. As several commenters indicate, ensuring the sharing of appropriate IBR modeling data is critical to create and maintain the models used in reliability studies, and in turn to ensure that Bulk-Power System transmission planners or operators are able to plan for, operate, and reliably integrate IBRs onto the Bulk-Power System. 77. With regard to AEU and ACP/SEIA's comments that the Commission direct NERC to specify data sharing requirements from transmission owners to generator owners and operators, we believe that this request may already be addressed through each transmission planner's existing processes. For example, the New York Independent System Operator (NYISO) and CAISO both have processes for obtaining such data after demonstrating a need for the specific information requested and that the required information protection and non-disclosure agreements are signed. 158 Nevertheless, to support accurate modeling and performance, we direct NERC to consider during its standards development process AEU and ACP/SEIA's suggested data sharing requirements when developing the framework, criteria, and necessary data exchange requirements to meet the registered IBR data sharing directive. 158 See NYISO, What to expect when submitting a CEII Request form (Sep. 9, 2021), https://nyiso.force.com/MemberCommunity/s/article/What-to-expect-when-submitting-a-CEII-Request-form; CAISO, Application access, http://www.caiso.com/participate/Pages/ApplicationAccess/Default.aspx (explaining that the process for secure planning and market systems data are available upon compliance with the applicable submission instructions and submittal of a non-disclosure agreement). 78. Commenters raised general concerns that mandating specific modeling and data submissions would reduce the flexibility and discretion of transmission planners and operators to identify the information they need. We find that, given the need for IBRs to operate in a predictable and reliable manner to ensure the reliable operation of the Bulk-Power System, it is necessary to establish uniform, minimum categories or types of data that must be provided so that Bulk-Power System planners and operators can predict the behavior of all IBRs. As discussed in more detail in section IV.C of this final action, we are also directing NERC to develop new or modified Reliability Standards that require the use of approved industry IBR models that accurately reflect the behavior of all IBRs during steady state, short-circuit, and dynamic conditions. 79. With regard to SPP's comment that some IBR data (and IBR-DER data) may be considered proprietary (user-defined) by manufacturers and difficult to obtain, we believe that the directives in this final action should facilitate the provision of IBR data and address these concerns further in the determination section IV.C.1 of this final action. 80. The Commission did not propose in the NOPR to address new cyber or physical security protections of IBRs beyond those in existing applicable Reliability Standards. Therefore, while we decline to direct NERC to develop IBR-specific cyber or physical security Reliability Standards for IBRs in this effort, NERC should evaluate whether there are gaps that must be addressed. We decline to direct that the NERC E-ISAC facilitate all IBR data sharing, as these suggestions fall outside the scope of this proceeding. 2. Disturbance Monitoring Data Sharing 81. In the NOPR, the Commission proposed to direct NERC to develop new or modified Reliability Standards that include technical criteria for disturbance monitoring equipment installed at buses and elements of registered IBRs to ensure disturbance monitoring data is available to Bulk-Power System planners and operators for analyzing disturbances on the Bulk-Power System and to validate registered IBR models. 159 159 NOPR, 181 FERC ¶ 61,125 at P 78. a. Comments 82. NERC, ACP/SEIA, CAISO, Indicated Trade Associations, and NYSRC support the proposed directive regarding disturbance monitoring data. 160 NERC agrees that disturbance monitoring data is fundamental for model validation and post-event analysis activities, and to identify reliability risks. NERC and Indicated Trade Associations both point to NERC Project 2021-04 (Modifications to Reliability Standard PRC-002-2), a NERC standard development project to modify disturbance monitoring and reporting requirements so that Bulk-Power System-connected IBRs are monitored in order to better assess disturbances. 161 NERC explains that the currently effective Reliability Standard PRC-002-2 was originally written with synchronous generation in mind, as that was the predominant form of generation in use at the time. 162 Thus, NERC explains that it is necessary to update currently effective Reliability Standard PRC-002-2 so that it requires registered IBRs to provide minimum disturbance monitoring data 163 to the planning coordinator or reliability coordinator, Regional Entity, or NERC. 160 See NERC Initial Comments at 9; ACP/SEIA Initial Comments at 12; CAISO Initial Comments at 39-40; Indicated Trade Associations Initial Comments at 6; NYSRC Initial Comments at 2. 161 NERC Initial Comments at 9; Indicated Trade Associations Initial Comments at 6. 162 See NERC Initial Comments at 9. 163 Disturbance monitoring data collection may include sequence of events recording, digital fault recording, synchronized phasor measurement unit recording, inverter oscillography recording data, and inverter and plant-level fault codes. 83. CAISO encourages the Commission to direct NERC to consider requiring IBRs to provide additional data, whether through telemetry collections or other automated platform integrations, to enhance real-time visibility of Bulk-Power System operations. 164 164 CAISO Initial Comments at 40. 84. ACP/SEIA agree with the proposed disturbance monitoring directive but caution that there is a need to balance the burden to the generator of collecting and providing the data with the benefit of that data to reliability, e.g., requiring high-speed data collection from every inverter at a plant is unnecessary because each inverter would provide nearly identical data. 165 165 ACP/SEIA Comments at 12. b. Commission Determination 85. Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR proposal to direct NERC to include in the new or modified Reliability Standards technical criteria to require registered IBR generator owners to install disturbance monitoring equipment at their buses and elements, to require registered IBR generator owners to provide disturbance monitoring data to Bulk-Power System planners and operators for analyzing disturbances on the Bulk-Power System, and to require Bulk-Power System planners and operators to validate registered IBR models using disturbance monitoring data from installed registered IBR generator owners' disturbance monitoring equipment. 166 We agree with NERC that updating Reliability Standard PRC-002-2 to apply to registered IBRs for disturbance monitoring data collection, including recording sequence of events, digital faults, synchronized phasor measurements, inverter oscillography, inverter and plant-level fault codes, and data retention, could be one way to accomplish this directive. We further agree with the findings in NERC reports ( e.g., a lack of high-speed data captured at the IBR or plant-level controller and low-resolution time stamping o [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2023-23581. Public record. Not legal advice.