The North American Electric Reliability Corporation (“NERC”) is developing an expansion of its registration requirements to include certain owners and operators of inverter-based resources by creating a new registered entity function, called the “GO-IBR.”
The GO-IBR is proposed to include inverter-based resources that “(1) have an aggregate nameplate capacity of less than or equal to 75 MVA and greater than or equal to 20 MVA interconnected at a voltage greater than or equal to 100 kV and (2) have aggregate nameplate capacity of greater than or equal to 20 MVA interconnected at a voltage less than 100 kV.” NERC, 183 FERC ¶ 61,116 at PP 13, 24 (2023). The proposed GO-IBR designation does not include inverter-based resources that connect to the local distribution system and it does not address inverter-based resources that are distributed energy resources.
The GO-IBR registered entity function and associated NERC registration and compliance requirements are not yet effective. They are being implemented over a three-year period. During that period, NERC will file progress reports with the Federal Energy Regulatory Commission (“FERC”) every 90 days. Within 12 months, NERC will modify its registration process, within 24 months NERC will identify unregistered owners and operators of inverter-based resource that meet the new GO-IBR registration criteria, and within 36 months NERC will register owners and operators of inverter-based resource that are subject to the GO‑IBR registration requirement. NERC, 183 FERC ¶ 61,116 at PP 17, 38, 52-53 (2023).
Under the proposed GO-IBR registered entity function, many owners and operators of wind, solar, and battery storage facilities that were previously not required to register with NERC may be required to register as a GO-IBR. As a general matter, wind, solar, and battery storage facilities with an aggregate nameplate capacity of 20 MVA or greater should monitor GO-IBR developments, as they may become subject to NERC registration and compliance requirements. Analysis of whether the GO-IBR will apply is fact specific and should be evaluated separately for each facility. Additionally, in the future the GO-IBR designation may need to be listed as a “governmental approval” or “material permit” in acquisition, financing, and investment transaction document schedules.
FERC’s recent order on NERC’s GO-IBR Registration Work Plan is available here and additional materials are available in FERC Docket No. RD22-4.
Sylvia Bartell and Husch Blackwell, LLP’s energy regulation specialists can assist with questions about NERC registration requirements and GO-IBR developments.